Introduction

This policy sets out AEDC’s expectations when employees or any other of its stakeholders become aware of circumstances which are not in compliance with any of its policies, laws, external rules, or regulations.

Policy Statement

The Board and Management of Abuja Electricity Distribution PLC (“AEDC” or “the Company”) are committed to making it an acceptable practice for shareholders, employees, consultants/contractors, suppliers, the Board of Directors, customers/business partners and other stakeholders of the communities in which the Company operates to raise concerns about unethical conducts relating to the Company’s business by any director, shareholder, employee, or consultant/ contractor.

Reportable Conduct

Illegal conduct: Any conduct that contravenes the laws of the Federal Republic of Nigeria or applicable international laws.

Non-procedural conduct: Any conduct that violates the Company’s established policies, rules, processes, and practices.

Other ethics-related activities or violations such as:

• Insider dealing and illegal information brokerage
• Conflicts of interest and abuse of office, improper business conduct
• Misuse of physical and information assets
• Sexual harassment
• Failure to comply with any legal obligation
• A miscarriage of justice
• Fraud, financial irregularities and all forms of bribery and corruption
• Suppressed past criminal records
• Purchase of goods at inflated prices, inferior goods or contract splitting
• Override of controls/ Abuse of authority
• Crime and any other unethical practice
• Abuse of any nature

Any personal grievances experienced by an employee, which should be pursued through their respective line managers, should not be misconstrued as a matter of whistleblowing.

How to Raise a Concern

As a first step, whistle-blowers should raise concerns with their line managers or superiors (Internal). This however depends on the seriousness and sensitivity of the issues involved and who is thought to be involved in the malpractice.

Concerns (Internal and external) can be raised in writing. Written concerns should set out the background and history of the concern, giving names, dates, and places (if known). To ensure the confidentiality of any expression of concern, it is suggested that a whistle blower either sends a letter/written note in a sealed envelope addressed to the Chief Internal Auditor (CIA) and clearly marked as “Strictly Private and Confidential – To be opened by addressee only” or,

Whistle blowers can raise their concerns through the following dedicated channels:

• Toll free hotline: 0800-TIP-OFFS (0800-847-6337).
• Web Portal: https://tip-offs.deloitte.com.ng.
• E-mail : tip-offs@deloitte.com.ng.
• Mobile App: Download Deloitte Tip-offs Anonymous App on Android or iOS devices.

Whistleblowers do not need to sign or give their names. However, where such is done, the Internal Auditor/independent Host may exercise discretion on whether to proceed with the investigation as an anonymous complaint.

Safeguards and Whistle-blower Protection

AEDC recognizes that the decision to report a concern can be a difficult one to make, mainly because of the fear of reprisal from those responsible for the alleged malpractice.

The Company, in its bid to drive the highest possible standards of transparency, probity and accountability will not tolerate harassment or victimization of a whistle-blower and will take action to protect any employee who raises a concern in good faith.

The Company will treat in strict confidence any concerns raised by employees and other stakeholders regarding actual or potential infractions.

The Company will also protect the identity of any persons who raise concerns and do not want their names disclosed.

Untrue Allegations

Any allegation made in good faith, but not confirmed on the investigation, carries no penalty. However, where an allegation is frivolous, malicious or for personal gain, disciplinary action may be taken against the whistle-blower.

Applicability

The Whistle Blowing Policy is applicable to all AEDC employees, the Board, Vendors, Customers or Business Partners, and any other stakeholder who has an interest in the Company.