Whistle Blowing Policy
Ikeja Hotel Plc
1. Introduction
Ikeja Hotel Plc (“IHP” or “the Company”) is committed to maintaining the highest standards of integrity, transparency, accountability, and ethical conduct across all its operations. The Company encourages employees, stakeholders, contractors, vendors, and other relevant parties to report concerns regarding any suspected misconduct, unethical behavior, malpractice, fraud, corruption, violation of laws, or any activities that may negatively impact the Company or its stakeholders.
This Whistleblowing Policy provides a secure and confidential framework for reporting concerns without fear of retaliation or victimization.
2. Purpose of the Policy
The objectives of this Policy are to:
- Encourage individuals to report genuine concerns regarding misconduct or unethical practices.
- Provide guidance on how to raise concerns appropriately.
- Ensure concerns are investigated fairly and professionally.
- Protect whistle-blowers from retaliation, harassment, or victimization.
- Promote a culture of accountability, integrity, and transparency.
3. Scope of the Policy
This Policy applies to:
- Employees
- Directors
- Consultants
- Contractors
- Vendors
- Service providers
- Business partners
- Other stakeholders associated with Ikeja Hotel Plc
The Policy covers concerns relating to:
- Fraud and financial misconduct
- Bribery and corruption
- Theft or misappropriation of assets
- Violation of laws or regulations
- Abuse of authority
- Health and safety violations
- Conflict of interest
- Unethical conduct
- Harassment or discrimination
- Concealment of wrongdoing
- Any other improper conduct affecting the Company
4. Reporting a Concern
4.1 Internal Reporting
Employees and stakeholders are encouraged to raise concerns as soon as possible through the appropriate reporting channels.
Reports may be made:
- Verbally
- In writing
- Via email
- Through designated hotline channels
4.2 Confidentiality
All disclosures made under this Policy will be treated confidentially to the extent reasonably practicable.
The identity of the whistle-blower will be protected, provided the disclosure is made in good faith.
4.3 Anonymous Reporting
While the Company encourages open reporting, whistle-blowers may choose to remain anonymous.
Anonymous reports may be submitted through:
Email:
Dedicated Hotline:
09129783367
Any report received through these channels will be reviewed only by the Company Secretary / Chief Compliance Officer.
Anonymous reporting may, however, make investigation more challenging where insufficient information is provided.
4.4 Protection Against Retaliation
Ikeja Hotel Plc strictly prohibits retaliation, victimization, intimidation, or harassment against any person who raises a concern in good faith under this Policy.
Any employee found engaging in retaliatory conduct may be subject to disciplinary action.
4.5 Meetings & Representation
An employee who raises a concern may request to be accompanied by:
- A colleague
- A friend
- A relative
- A representative
at any meeting convened under this Policy.
All accompanying persons must maintain strict confidentiality regarding the disclosure and any investigation process.
4.6 Written Records
The Company may prepare a written summary of the concern raised and provide a copy to the whistle-blower upon request.
The whistle-blower may also receive an indication of how the Company intends to address the matter.
5. Investigation & Outcome
5.1 Initial Assessment
Upon receiving a report, the Company Secretary / Chief Compliance Officer will conduct an initial assessment to determine whether:
- The concern is credible
- Further investigation is required
Where the report is not anonymous, the whistle-blower may be informed of the assessment outcome and may be requested to provide additional information.
5.2 Investigation Process
The Company may appoint:
- Internal investigators
- Human Resources personnel
- External investigators
- Other qualified professionals
to conduct investigations where necessary.
Where criminal activity is identified, the Company reserves the right to notify appropriate law enforcement authorities.
5.3 Confidentiality During Investigation
The Company aims to keep the whistle-blower informed regarding:
- Investigation progress
- Expected timelines
- Outcomes where appropriate
However, confidentiality obligations may limit the extent of information disclosed during the process.
All parties involved are expected to maintain strict confidentiality.
5.4 Board-Level Escalation
The Company Secretary / Chief Compliance Officer shall review all reported cases and escalate matters to:
- Executive Management
- Relevant Committees
- The Board of Directors
where necessary and appropriate.
6. False & Malicious Reports
Any person found to have knowingly made false, malicious, or misleading allegations under this Policy may be subject to disciplinary action or legal consequences.
Reports must always be made honestly and in good faith.
7. Policy Administration
The Company Secretary / Chief Compliance Officer shall be responsible for:
- Monitoring compliance with this Policy
- Managing whistleblowing reports
- Maintaining records
- Ensuring investigations are properly conducted
- Reporting significant matters to Management and the Board
8. Policy Review
This Policy may be reviewed periodically to ensure continued effectiveness and alignment with regulatory requirements, corporate governance standards, and best practices.
Contact Information
Whistleblowing Reporting Channels
Email:
Hotline:
09129783367
Confidentiality Notice
All disclosures made under this Policy shall be handled with the highest level of confidentiality and professionalism in accordance with applicable laws and corporate governance standards.