Updated on: August 16, 2022
1. Definitions
In this document:
1.1 " Board" means the Board of Directors of Tangerine
1.2 " Policy" this whistleblowing policy
1.3 " Subsidiary" means any company in which Tangerine holds more than 50% of the issued share capital whether directly or indirectly
1.4. " Tangerine" means Tangerine Financial Limited
1.5 "Tangerine Board Committee(s)" means the Committee(s) established by the Board of Directors of Tangerine from time to time
1.6 " Tangerine CEO" means the Chief Executive Officer of Tangerine
1.7 " Tangerine Group" or " the Group" means Tangerine and all its subsidiaries
2. Introduction
2.1 Tangerine Group is committed to ethical and fair business conduct and does not tolerate any form of dishonesty, fraud, theft, corruption, malpractices or unethical behaviour in its operations. The Company requires Staff and all Parties that have business relationship with it to, at all times, act honestly and with integrity and to safeguard the Company's resources (tangible and intangible) for which they are responsible.
2.2 Tangerine Group has a zero tolerance to the commission or concealment of fraudulent, illegal, and unethical acts, including infraction of its business principles as well as other ethics related policies of the Company.
2.3 Therefore, all employees, consisting of permanent staff, contract staff, unconfirmed staff, agents, interns and Youth Corp Members, acting for and on behalf of the Company, are required to, without fear of reprisal, disclose actual, potential or suspected instances of malpractice to an internal source, as provided for within this Policy.
2.4 This disclosure requirement also extends to the Company's business associates and other external Stakeholders, such as contractors, consultants, suppliers, shareholders, clients, regulators, amongst others.
3. Purpose
3.1 Whistleblowing is the act of disclosing or raising concerns about misconduct or other actions affecting the Company, or occurring within the Company, and which could endanger the Company and its employees or threaten its client's, shareholders, or the public.
3.2 The act of whistleblowing is an invaluable source of early warning, which alerts the Company to incidents that could be of negative consequences. It therefore serves as a useful tool in the identification and management of risk.
3.3 The purpose of the Whistleblowing Policy is to ensure strict compliance with Tangerine Group's zero tolerance to fraudulent, illegal, and unethical acts, thereby protecting the Company's interest as well as that of its clients and shareholders.
3.4 Accordingly, the Whistleblowing Policy is intended to encourage and facilitate the disclosure of any form of misconduct to an authorised officer, via an approved means.
3.5 This policy aims to:
Encourage employees to feel confident in raising serious concerns, and to question or act upon concerns about malpractices.
Provide avenues for employees to raise those concerns and receive feedback on any action taken.
Ensure that concerns expressed are given proper consideration.
Reassure employees that they will be protected from possible reprisals or victimization where there is reasonable belief that a disclosure has been made in good faith.
3.6 The Tangerine Group encourages that the whistleblowing channels be taken as the last resort while business-as-usual matters could be taken up with line managers.
4. Open Culture
4.1 The Tangerine Group upholds a culture of openness, transparency, and accountability, hence, the Company encourages an open and positive approach to whistleblowing.
4.2 Rather than ignoring a problem, employees, business associates and other stakeholders alike, are encouraged to disclose all reportable events that come to their notice, with the assurance that all information provided will be treated as confidential in nature and only shared with appropriate parties.
4.3 The Company shall investigate all allegations and issues of serious concern brought to its notice and shall take appropriate actions to address such concerns.
4.4 Consequently, employees who do not comply with the provisions of the Policy could be subject to appropriate disciplinary actions.
5. Related Documents
Tangerine Group Code of Ethics and Conflict of Interests Manual
6. Scope
6.1 The Whistleblowing Policy provides for the reporting of all genuine concerns within any aspect of the Company's operations and involving employees or any party that has a business relationship with Tangerine Group. These concerns shall include:- Conduct that is against the Tangerine Group code of conduct, rules, procedures, and policies, or established standards of practice;
Conduct that amounts to fraudulent or illegal act as defined within the Tangerine Group Code of Ethics and Conflict of Interests Manual including theft and corrupt practices.
Unethical conduct according to measures of standard practice within the Company.
Conduct that amounts to misuse of Tangerine Group's resources, including business information.
Conduct that makes you feel uncomfortable in terms of your experience with the standards you believe the Company upholds;
Conduct that amounts to wilful or negligent instances of non-performance of duties including abuse of office;
Health and safety violations
Insider dealing and illegal information brokerage
Commission of a crime
Failure to comply with any legal obligations
A miscarriage of justice
Damage to the environment
6.2 Conduct becomes reportable when it happens or when it is reasonably likely to occur.
6.3 The Company may be endangered if any of these conducts is left unchecked. Importantly, in determining whether to disclose a reportable incident, harm done to the Company is not solely measured in terms of financial loss or damage to a particular business, but harm is equally measured with regards to any damage done to the Company's integrity and reputation.
7. Confidentiality
7.1 All information obtained from a Whistleblowing Report shall be considered confidential and would not be disclosed or discussed with other persons, except for the purpose of the investigation or where the Company has a legal or regulatory obligation to disclose.
7.2 Any individual, who reports, provides or obtains information as part of the investigation of a reported misconduct must not disclose or discuss the information or the investigation with other persons, internal or external.
7.3 Any breach of this Confidentiality would be treated in accordance with the Disciplinary Process as stipulated within the Tangerine Group Staff Manual.
8.Reporting
An individual who observes, or becomes aware of a reportable misconduct, as defined within the Policy, has an obligation to report that conduct. Reports must be made in accordance with the requirements stipulated below.
8.1 Whistleblowing Channels
The channels and procedures for whistle blowing or raising complaints shall depend on whether the allegation, complaint or information is being made or disclosed by a staff member or by a party external to the Company.
Staff Members
Staff members are expected to whistle blow on transactions, operations and any other activities of the Company that involve fraud, corruption and misconduct, whether internal or external via the dedicated email address tangerineafrica.whistleblow@oalpconsulting.com
External Parties
Parties external to the Company, however, are required to bring allegations and complaints of corruption, fraud and any other misconduct in the execution of any business of the Company or project(s) related to the Company to the knowledge of the Company via the Whistleblowing link on the Company's website or send an email to tangerineafrica.whistleblow@oalpconsulting.com
All communications made via the dedicated email address and the whistleblowing portal will be received by the Head of Internal Audit, Chief Compliance Officer and Managing Director/CEO.
8.2 Minimum Information Required for a Whistleblowing Report
1. Name of officer(s) involved
2. Nature of misconduct
3. Date of occurrence
4. Estimated value of loss to the Company (if any)
5. Specific evidence of occurrence of the misconduct
9. Confidential & Anonymous Whistleblowing
The Company wishes to assure the safety of whistleblowing, and therefore provides whistle blowers with the option of either confidential whistleblowing or anonymous whistleblowing.
9.1 Confidential Whistleblowing
A whistle blower is encouraged to reveal his or her identity when a report or disclosure is made using any of the channels mentioned above. This approach helps the investigation significantly, as the Whistle blower can be contacted to provide further details on the report, where necessary.
9.2 Anonymous Whistleblowing
However, a whistle blower may choose not to reveal his or her identity upon making a report. With the reporter's anonymity thus assured, the identity of the reporter cannot be ascertained by anyone. Should this approach be chosen, the Whistle blower must ensure that enough information is provided to enable a thorough investigation.
Whistle blowers should endeavour not to discuss the details of the reported misconduct with other persons, except as part of the investigation to ensure the protection of all parties involved and not to jeopardise the investigation process.
10. Whistle blower Protection
10.1 An employee making a Whistleblowing Report in good faith may do so without fear of retaliation or occupational prejudice. However, this protection is forfeited if it is found that the report was deliberately falsified or made with malicious intent.
10.2 Retaliation and occupational prejudice are in themselves misconducts, and when established, must be immediately escalated to the Audit and Compliance Units and would be handled through appropriate disciplinary proceedings as stipulated in the Tangerine Group Staff Manual.
11. False Allegations & Complicity
11.1 Falsified and malicious allegations made through the Whistleblowing System would be considered misconduct and, when established, would result in disciplinary actions taken against the employee as stipulated within the Tangerine Group Staff Manual.
11.2 Reporting under this policy does not immunize or shield a whistle blower against action following from his or her intentional misconduct, which includes wilfully participating in the reported misconduct.
12. Investigation and Follow-up
12.1 The Company is committed to investigating and addressing all cases of reported misconduct. Instances of suspected fraud and corrupt activities shall be investigated in accordance with the Tangerine Group Staff Manual.
12.2 All other instances of misconduct shall be assessed by the Internal Audit unit and referred to the appropriate Unit for investigation and necessary action. The Internal Audit unit shall follow-up to ensure that the report is properly investigated and adequately addressed.
12.3 All persons involved in the investigation of a reported suspicion in accordance with this policy will have access to all records, data, and information pertaining to the investigation.
12.4 Failure of any employee to assist in an investigation; or an intentional obstruction of the progress of an investigation by an employee would be considered a breach of contract and may result in disciplinary actions taken against the employee.
12.5 Interaction with law enforcement agencies would occur as it is deemed necessary and in accordance with the Tangerine Group Anti-Fraud Policy. As appropriate, relevant regulators will be informed of allegations and the subsequent outcome of investigations.
12.6 The whistle blower may seek follow-up information about the investigation of a report, escalated using the confidential whistleblowing option, or any consequent action taken by Tangerine Group.
13. How to Raise Concerns
13.1 As a first step, business-as-usual activities could be taken up with line managers or superiors. This however depends on the seriousness and sensitivity of the issues involved and who is thought to be involved in the malpractice. For example, if it is believed that Management is involved, the Internal Audit Team or Human Resources should be approached.
13.2 Concerns are better raised in writing but if the whistle blower does not feel comfortable to put his or her concern in writing, the Internal Auditor or any other designated officer as may be applicable may at his/her discretion decide to receive a complaint made by telephone or in person at a meeting. Written concerns should set out the background and history of the concern, giving names, dates and places (if known). In order to ensure the confidentiality of any expression of concern it is suggested that Whistle Blowers send their letter/written note in a sealed envelope addressed to the Internal Auditor and clearly marked as "Strictly Private and Confidential - To be opened by addressee only."
14. Escalation
Reported misconducts involving an employee shall be escalated to the Head, Internal Audit and the employee's Line Manager
Reported misconducts involving a Departmental Head shall be escalated to the Head, Internal Audit and the MD/CEO.
Reported misconducts involving a member of Senior Management, with the exception of the Chief Compliance Officer, the Head Internal Audit or the MD/CEO, shall be escalated to the Head Internal Audit or the MD/CEO,
Reported misconducts involving the Chief Compliance Officer, the Head Internal Audit or the MD/CEO shall be escalated to the Chairperson, Board Audit and Compliance Committee.
15. Assurance
The Internal Audit Unit has the responsibility of auditing the processes related to the reporting and investigation of all misconducts reported in accordance with the Whistleblowing Policy.
16. Monitoring and Reporting
16.1 The Internal Audit Unit shall be responsible for monitoring and reviewing whistleblowing activities.
16.2 Reports on whistleblowing information shall be provided to Senior Management on a monthly basis and to the Board Audit and Compliance Committee on a quarterly basis.