Last updated: December 2025
Dayspring Microfinance Bank Limited maintains a high ethical standard and has a code of ethics, expecting all stakeholders to comply.
The Dayspring MFB Whistleblowing Policy and Procedure offers a confidential channel for bank employees and other stakeholders to report workplace malpractices, enabling the institution to investigate and address them.
Whistleblowing is the act of reporting perceived unethical conduct by employees, management, directors, and other stakeholders to appropriate authorities. This manual outlines the bank's policy and procedures for investigating and dealing with illegal and unethical conduct.
This policy complies with regulatory requirements, specifically referencing section 3.1 of the Central Bank of Nigeria (CBN) "Guidelines for whistleblowing for banks and other financial institution in Nigeria" and section 5.3.1 of "Code of Corporate Governance for Banks and Discount Houses," both dated December 1, 2018.
This policy and procedure manual aims to encourage staff and stakeholders to report perceived unethical or illegal conduct confidentially, without fear of harassment, intimidation, victimization, or reprisal.
a. To ensure all employees feel supported in speaking up confidentially about suspected improper, unethical, or inappropriate conduct within the bank.
b. To enable the identification and challenge of all improper, unethical, or inappropriate behavior at all levels of the organization.
c. To provide clear procedures for reporting and handling such concerns.
d. To proactively prevent and deter misconduct that could impact the bank's financial performance and reputation.
e. To provide assurance that all disclosures will be handled seriously, confidentially, and without fear of reprisal.
f. To help promote and develop a culture of openness, accountability, and integrity.
This policy and procedure manual is designed to enable employees and other relevant stakeholders to report any perceived act of impropriety, which should not be based, on mere speculation, rumors and gossips but on knowledge of facts. Reportable misconducts covered under this policy include:-
a. All forms of financial malpractices or impropriety such as fraud, corruption, bribery, theft and concealment;
b. Failure to comply with legal obligations, statutes, and regulatory directives;
c. Actions detrimental to Health and Safety or the work environment;
d. any form of criminal activity;
e. Improper conduct or unethical behavior that undermines universal and core ethical values such as integrity, respect, honesty, accountability and fairness;
f. Other forms of corporate governance breaches;
g. Connected transactions not disclosed or reported in line with regulations;
h. Insider abuse;
i. Non-disclosure of interests;
j. Sexual or physical abuse of staff, customers, prospective staff, service providers and other relevant stakeholders; and
k. Attempt to conceal any of the above listed acts.
The above listed reportable misconducts or concerns are not exhaustive. However, judgment and discretion are required to determine misconduct that should be reported under this policy. The general guide in identifying reportable misconduct is to report concerns which are repugnant to the interest of the bank and the general public and appropriate sanctions applied.
This policy covers the activities of Dayspring MFB and the entire department within the bank. This is without prejudice to the requirements by regulators to put in place their respective whistleblowing policies. Furthermore, the policy shall also be read in conjunction with the whistleblowing guidelines that may be issued by relevant regulatory agencies with oversight on the operations of the Institution.
The Board and Management believe that a robust internal system for employees and other relevant stakeholders to disclose workplace malpractices without fear of reprisal shows that employees take their responsibilities seriously, and helps to avoid the negative publicity that often accompanies disclosures to external parties.
Hence the Board of Directors and Management is committed towards promoting a culture of openness, accountability, and integrity, and will not tolerate any harassment, victimization or discrimination of the whistleblower provided such disclosure is made in good faith with reasonable belief that what is being reported is fact.
Dayspring MFB is committed to the highest standards of openness, probity, accountability, and high ethical behavior by helping to foster and maintain an environment where employees and other stakeholders can act appropriately, without fear of reprisal. To maintain these standards, the Dayspring MFB encourages employees and relevant stakeholders who have material concerns about suspected misconduct or any breach or suspected breach of law or regulation that may adversely impact the bank to come forward and report them through appropriate channels (in certain cases on a confidential basis) without fear of retribution or unfair treatment.
Dayspring Microfinance Bank Limited conducts its business on the principles of fairness, honesty, openness, decency, integrity, and respect. It is the intention of this policy to encourage employees and other relevant stakeholders to report and disclose improper or illegal practices or activities. The bank is committed to investigate promptly any reported misconduct and to protect those who come forward to report such activities. This Institution further assures that all reports shall be treated in strict confidence.
Dayspring MFB operating procedures are intended to detect and prevent or deter improper activities. However, the best systems of controls may not provide absolute safeguards against irregularities. This policy is intended to investigate and take appropriate action against any reported misconduct or concern.
The following are the roles and responsibilities of the various parties in the whistleblowing process:
a. Whistleblower - Whistleblowers are expected to act in good faith and should refrain from making false accusations when reporting his/her concern(s), and provide further evidence at his/her disposal to aid investigation of the issues reported.
b. Suspect - Suspect has a duty to cooperate during the period of investigation including provision of relevant information, documents or other materials as may be required by the investigator.
c. Investigator/Head, Internal Audit, Dayspring MFB. - The Head, Internal Audit is expected to handle all matters professionally, confidentially and promptly. She/he shall be independent and unbiased in carrying out investigation.
The Head, Internal Audit has the responsibility of acknowledging all concern(s) reported and reporting on the progress of investigation to the whistleblower.
The Head, Internal Audit shall on a quarterly basis provide to the Chairman of the Board Audit & Risk Assessment Committee a summary of all cases reported and the result of the investigation.
The Head, Internal Audit/Investigator shall refrain from discussing or disclosing matters under investigation.
d. Head of Human Resources - The Head of Human resources of Dayspring Microfinance Bank shall handle the report of investigation that relates to the bank's employees in line with the laid down disciplinary procedure as contained in the staff hand book.
e. Board Audit and Risk Assessment Committee - The Chairman, Board Audit and Risk Assessment Committee through the Company Secretary shall make available to all committee members quarterly report submitted by the Head, Internal Audit on whistleblowing, and treat all whistleblowing concern(s) brought to the attention of the committee with dispatch.
f. Head, Risk Management of Dayspring MFB - Review, update the whistleblowing policy and procedure and obtain requisite Board approval.
The whistleblowing procedure involves steps that should be taken by the whistleblower in reporting misconduct, and steps required for the investigation of the reported misconduct. The following procedures shall guide the whistleblowing process:
Internal whistleblowing involves staff raising concerns about unethical conduct. The following procedure shall be adopted for the purpose of internal whistleblowing:
An internal whistleblower may raise concern through any of the following media (this can be done either by declaration or in confidence/ anonymously):
• Formal letter to the Managing Director of Dayspring MFB or the Head of Internal Audit,
• Dedicated phone number/communicator chat.
• Dedicated email address:
• Via Dayspring MFB website:
Where the concern is received by staff other than the Managing Director or the Head, Internal Audit, the recipient of such concerns shall be required to;
• Immediately pass the concern(s) to the Head, Internal Audit with copy to the Managing Director, Dayspring MFB.
• If the concerns affect the Head of Internal Audit, the Managing Director, Dayspring MFB shall be notified; and where a Director is involved, such concern shall be directed at the Chairman Board Audit & Risk Assessment Committee.
The concern(s) shall be presented in the following format;
■ Background of the concerns (with relevant dates)
■ Reason(s) why the whistleblower is particularly concerned about the situation.
Disciplinary measures in line with the staff handbook shall be taken against any staff that receives concerns and fails to escalate. Also, disciplinary measure shall be taken against an internal whistleblower who acted out of malice.
The Head, Internal Audit shall on receipt of the concern(s) acknowledge receipt of the concern from the whistleblower within 2 working days, and immediately commence investigation. The purposes of investigation are to:
• Establish if a wrongdoing has occurred based on the concern(s) raised, and if so to what extent; and
• To minimize the risk of further wrongdoing, prevent any further loss of assets, damage to the bank's reputation and if possible protect all sources of evidence.
If preliminary investigation shows that the concern falls within the whistleblowing reportable concerns, then further investigation shall be carried out. If otherwise or the concern is outside the reportable misconduct, then the Head, Internal Audit shall refer the matter to appropriate quarters for further action.
Where necessary the Head, Internal Audit shall provide update of the progress of investigation to the whistleblower if the concerns fall within the reportable concerns. Finally, if the concern raised by the whistleblower is frivolous or unwarranted, the Head, Internal Audit shall ignore such concern, and where necessary disciplinary measure in line with Human Resources policy shall apply to staff involved.
Upon conclusion of investigation, the Head, Internal Audit shall submit his/her report to the Human Resources or the appropriate authority for further action(s). Where necessary the Head, Internal Audit shall escalate to the bank Managing Director. However, quarterly report to keep the bank Managing Director abreast of developments in whistleblowing shall be submitted by Head, Internal Audit.
All disciplinary action relating to the report shall follow the bank's disciplinary procedure as contained in the staff hand book.
If the whistleblower is not satisfied with the extent of investigation and or the action taken based on the outcome of the investigation, the whistleblower is at liberty to report to the Chairman of the Board Audit and Risk Assessment Committee.
Any internal whistleblower that feels victimized can report his/her grievance(s) to the Chairman, Board Audit and Risk Assessment Committee. This is without prejudice to the fundamental right of the internal whistleblower to seek redress in the court of law.
The bank shall handle all investigations promptly and fairly. The Head, Internal Audit shall ensure that investigations are concluded within four (4) weeks of receipt of the concern(s). Where resolution is not achieved within the four (4) weeks, the Head, Internal Audit shall report to the Managing Director and the Board Audit and Risk Assessment Committee.
It shall be the policy of the bank to protect whistleblowers who disclose concerns, provided the disclosure is made;
• In the reasonable belief that it is intended to show malpractice or impropriety;
• To an appropriate person or authority; and
• In good faith without malice or mischief.
The group shall consider the following factors in determining whether a disclosure is unanimous:
• Seriousness of the issues being reported;
• The significance and credibility of the concern; and
• The possibility of confirming the allegation.
Dayspring MFB shall not subject a whistleblower to any detriment. Where a whistleblower feels unfairly treated owing to his/her actions, the whistleblower shall be at liberty to report to the Central Bank of Nigeria and any other regulatory body with oversight on the bank`s businesses. This is without prejudice to the right to take appropriate legal action.
Where necessary, compensation of whistleblowers whether internal or external that have suffered detriment shall be at the discretion of Management taking into consideration regulatory guidance on compensation of whistleblower to be issued from time to time.
Any retaliation, including, but not limited to, any act of discrimination, reprisal, harassment, suspension, dismissal, demotion, vengeance, or any other occupational detriment, direct or indirect, recommended, threatened, or taken against a whistleblower because he/she has made a disclosure in accordance with this policy will be treated as gross misconduct and dealt with accordingly.
Whistleblowers must ensure that they do not make disclosure outside of the prescribed channels (e.g., media-print, or electronic), or their disclosures may not be protected.
A whistleblower whether internal or external may elect to disclose directly to any of the following regulatory bodies that have oversights on the activities of Dayspring MFB.
a. Central Bank of Nigeria (CBN)
Address: Central Business District. P.M.B 0187 Garki Abuja.
Phone: 09-46237401
e-mail: anticorruptionunit@cbn.gov.ng
b. Nigeria Deposit Insurance Corporation NDIC
Address: Nigeria Deposit Insurance Corporation NDIC Plot 447/448 Constitution Avenue Central Business District P.M.B. 284, Garki Abuja
Phone: (09) 460 1380 - 9 (09) 6171380 - 9
email: info@ndic.org.ng, helpdesk@ndic.org.ng
c. Securities and Exchange Commission (SEC)
Address: SEC Towers, Plot 272, Samuel Adesujo Ademulegun Street, Central Business District P.M.B:315 Garki Abuja.
Phone: +234 (0) 94621159
email: sec@sec.gov.ng
d. Nigeria Insurance Commission (NAICOM)
Address: SEC Towers, Plot 272, Samuel Adesujo Ademulegun Street, Central Business District P.M.B:315 Garki Abuja.
Phone: +234 (0) 94621159
email: sec@sec.gov.ng
e. National Pension Commission (PENCOM)
Address: Plot 174, Adetokunbo Ademola Crescent, Wuse, Abuja, Nigeria.
email: info@pencom.gov.ng
Phone: +234-9-4603930
While regulation and best practice in corporate governance requires entities irrespective of their size and location to have a whistleblowing policy, Dayspring MFB believes that simply having a whistleblowing policy is not enough to create a culture in which employees are genuinely encouraged to disclose unethical behaviors. In creating an enabling environment which ensures that whistleblowing regime is effective, the institution is required to adopt the following measures:
a. Board and Management commitment
The Board and Management of Dayspring MFB are expected to clearly support and sponsor whistleblowing. This will include respecting the policy and dedicating a senior management staff preferably the Head of Audit as the advocate for whistleblowing, who shall be authorized to implement and undertake investigation.
b. Communication and Training
All employees in bank should be aware of the existence of a whistleblowing regime. This can be achieved through regular compulsory training by Compliance Department, newsletters, emails and presentations. Annual declaration by all staff of having read and understood the policy shall also be encouraged.
c. Proper Investigation and Action
All whistleblowing disclosures or concerns must be investigated promptly and properly, and appropriate action taken upon conclusion of investigation. Furthermore, all whistleblowing investigation shall be kept confidential.
d. Feedback on effectiveness of Policy
Regular survey on the effectiveness of the policy should be conducted at regular interval preferably by Compliance Department. Such questions to gauge employee satisfaction or survey shall include:
• Have you read the whistle blowing policy?
• If yes, when last did you read the policy?
• Do you know who to contact to make disclosure?
• Do you feel you work in an open environment in which you are encouraged to speak up and you can safely voice any concerns without fear of reprisal?
• What would you change about how the policy operates?
• Are you comfortable with the name ("whistleblowing") of the policy?
• If No, what other name will you suggest?
e. Reward
Reward system to encourage a strong and effective whistleblowing culture can be institutionalized in the bank. Departments can be assessed on the average number of man hours training that the team attended on whistleblowing training.
This policy document remains the property of Dayspring MFB. However, its custody and management shall rest with the Head, Risk Management Department of Dayspring MFB who also has oversight on the Compliance function.
This policy document and procedure manual shall be subject to review every two (2) years or as may be deemed necessary. All suggestions for review and or amendments shall be forwarded to the Head, Risk Management, Directors of Dayspring MFB for necessary action.
Although this document shall be hosted in the official website of Dayspring MFB, the Management of the bank shall ensure strict compliance with this policy.
a. Complaint
An allegation or concern that is subject to investigation by the appropriate authority.
b. Detriment
Victimization or reprisal of a whistleblower which can take any or a combination of the following forms; dismissal, termination, redundancy, undue influence, duress, withholding of benefit and/or entitlements and any other act that has negative impact on the whistleblower.
c. Good Faith
This is evident when a report or concern is made without malice or consideration of personal benefit and the employee has a reasonable basis to believe that the report is true; provided, however, a report does not have to be proven to be true to be made in good faith. Good faith is lacking when the disclosure is known to be malicious or false.
d. Investigation
A process designed to gather and analyze information to determine whether misconduct has occurred and if so, the party or parties responsible.
e. Misconduct
A failure by a staff member or other relevant stakeholder to observe the rules of conduct or standards of behavior prescribed by an organization.
f. Suspect
A person who is alleged to have committed a misconduct and subject of investigation.
g. Whistleblower
Any person(s) including employee, management, directors, depositors, service providers, creditors and other stakeholders of an institution who reports any form of unethical behavior or dishonesty to the appropriate authority.
h. Whistleblowing
The act of reporting an observed/perceived unethical misconduct of employees, management, directors, and other stakeholders of an institution by an employee or other person to appropriate authority. It is an early warning system that enables an organization to find out when something is going wrong in time to take necessary corrective action.