FEDERAL MEDICAL CENTRE, GUSAU

WHISTLE BLOWERS’ POLICY

INTRODUCTION

The Federal Medical Centre Gusau as an organization under the Federal Ministry of Health keyed into the Federal Government of Nigeria’s policy of whistle blower by drafting its own policy on the programme.

By drafting the policy the Centre has created an enabling environment to encourage people to voluntarily disclose information about professional negligence, Maltreatment of patients/clients, sabotage, fraud, misconduct, bribery, corruption, looting Government or assets, engaging in any form of financial malpractice etc, which are committed by employees against the Centre.

The policy has provided detailed steps and procedures governing seamless implementation of the whistle blowing policy in the Centre. It has also put in place protective mechanisms for the disclosures as well as for the volunteers making the disclosures.

1.0             OBJECTIVES

Generally speaking, the Centre’s main objective in making the Whistle Blowers’ policy is to encourage staff and other relevant stake holders to report perceived unethical or illegal conducts of the management and employees in a confidential manner without fear of harassment, intimidation or victimization.

Specific objectives of the policy include the following:

a.     To eradicate unethical behavior in organization.

b.     To promote commitment to ethical behavior.

c.      To encourage culture where wrong doing is safely reported.

d.     To provide assurance that all disclosures will be handled seriously and confidentially managed without fear of victimization.

3.0. SCOPE OF THE POLICY

The policy is designed to enable employee of the Centre and relevant stakeholders to report any perceived act of impropriety which should not be on mere rumours or speculations but based on facts.

Conducts to be reported include:

a.     All forms of financial malpractice, such as fraud, corruption, bribery etc.

b.     Professional negligence of duty, unethical conduct and other acts of misconduct.

c.      Failure to comply with legal obligations, statutes and regulatory directives.

d.     Engaging in actions that are detrimental to Health and safety of the work environment.

e.     Any criminal activity

f.       Improper conduct or unethical behaviour that undermines the universal and core ethical values such as integrity, respect, honesty, accountability and fairness.

g.     Attempt to correct any of the above listed acts.

4.0.1. GOVERNING BOARD AND MANAGEMENT

It is important to state that both the Governing Board and Management of Federal Medical Centre Gusau are committed towards promoting a culture of openness, accountability and integrity and will not tolerate harassment, victimization or discrimination of the whistleblower.

4.0.2 UNFAIR TREATMENT OF WHISTLE BLOWER

     All empolyees are warned against treating Whistle Blowers unfairly. Employees caught in contravention of this will charged for misconduct will be tried in accordance with the Centre’s manual.

Unfair treatment of Whistle Blower includes the following acts:

Harassment, Victimisation, Discrimination, etc.

5.0. CATEGORIES OF WHISTLE BLOWERS AND THEIR ROLES

There are two categories of whistle blowers, namely; Internal Whistle Blower and External Whistle Blower.

Internal Whistle blowers-, This category involves employees of Centre report incidents or acts of misconduct involving their colleagues, superiors or Top Management Staff to relevant reporting point.

External Whistle blowers-This category involves reports made by non-staff which includes Patients/Clients, Suppliers, Service providers stake holders and other members of the public who report wrong doings of employees to the Chief Executive or the Compliance Officer.

6.0 WHISTLE BLOWING PROCEDURE

This Whistleblowing Procedure provides a mechanism for reporting any unlawful conduct at work and reassurance that exposing wrongdoing would not pose any risk to the whistleblower.

The whistleblower should however make it clear that they are making the disclosure within the scope of the whistleblowing policy to ensure that the recipient of the disclosure will be able to conduct investigation within the ambit of the policy and more importantly to ensure protection of identity of the whistleblower if required.

           6.01 INTERNAL WHISTLE BLOWING PROCEDURE

An Internal Whistle Blower may raise concerns either by declaration or anonymously through any of the following:

 -Formal letter to the Medical Director of Federal Medical Centre Gusau.

 -Call or text message one to the following dedicated Phone Numbers

08133833300

08028056411

08035927877

   -Physically meet the Medical Director

   -Physically meet the Chief Internal Auditor

   Through these email addresses: fmc.gusau@yahoo.com,fmcgusau2006@gmail.com

Changes to any of the channels detailed above would be promptly communicated to all stakeholders by the Centre through the approved channels after which the policy would be amended accordingly.

Where the concern is received by Staff other than the Medical Director or the Chief Internal Auditor, the Staff to whom the concern is directed shall be required to document and immediately forward the concern(s) to the Chief Internal Auditor with copy to the Medical Director.

If the concerns affect the Chief Internal Auditor, the Medical Director must be notified, and where such issues affect a member of Top Management Committee such concern shall be referred to the Chairman Board of Management or the Medical Director appropriate action within a reasonable time.

        6.0.2  REPORTING FORMAT  

           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. Supporting evidence for the allegations, if available, would be helpful in the investigation.

      6.0.3 INVESTIGATING PROCESS OF CONCERN(S) BY AN INTERNAL WHISTLE BLOWER

The Chief Internal Auditor shall within seven (7) days of receipt of the concern from the         whistle Blower or from any of the authorized channels:

-Acknowledge receipt of the issue(s) raised.

-Commence review to ascertain validity of claim and determine whether the concerns fall within the scope of whistle-blowing or not.

-The Chief internal Auditor will track the Turnaround time and provide further assurance on the investigation process.

-He/or She should establish if a wrongdoing has occurred based on the concern(s) raised, and if so, to what extent; and minimize the risk of further wrongdoing, prevent any further loss of assets, damage to the reputation of the Centre and if possible protect all sources of evidence.

He shall, upon conclusion of the investigation, submit a detailed report to the Medical Director for appropriate actions in line with the approved policies of the Centre.

-The Compliance Officer will track the Turnaround time and provide further assurance on the investigation process; for which responsibility, still rests with Internal Auditor.

Disciplinary sanctions must however be approved by the Management or

Board Members depending on the grade of the Staff involved and in line with the Staff Disciplinary Policy/Procedure.

Where necessary, the Chief Internal Auditor will keep the Whistleblower informed of progress and the outcome of the investigation, within the constraints of maintaining confidentiality or observing legal restrictions generally.

If dissatisfied with the outcome of the investigation, a Whistle blower may have recourse to the Medical Director or Board Chairman which will not affect the fundamental right of the of the internal Whistleblower to seek redress in the Court of law.

Furthermore, the Chief internal Auditor shall periodically submit a summary of reported cases and outcomes to the Medical Director or Chairman Board of the Centre.

6.0.4 EXTERNAL WHISTLE BLOWING PROCEDURE

An external Whistle blower are Clients/patients, suppliers, service providers, stakeholders and other members of the public who report wrong doings of employees to the Chief Audit Executive or the Medical Director. An external Whistle blower may raise concerns either by declaration or anonymously through any of the following:

-Formal letter to the Medical Director of Federal Medical Centre Gusau or the Chief Audit Executive.

-Call or text the following dedicated phone numbers:

·        Medical Director on 

·        Chief Audit Executive on

·        Dedicated whistle blowing e-mail:

·        Directly to the Medical Director of the Centre.

·        Directly to the Chief Audit Executive

Changes to any of the channels detailed above would be promptly communicated to all stakeholders by the Centre through the approved channels.

Where the concern is received by Staff other than the Medical Director and Chief Internal Auditor, the Staff to which the concern was directed shall be required to:

·        Document and immediately forward the concern(s) to the Chief Audit Executive with copy to the Medical Director.

·        If the concerns affect the Chief Audit Executive, the Medical Director would be notified, and where such issues affect the Medical Director or the Management, such concern shall be referred to the Board for appropriate action within a reasonable time.

6.0.5 REPORTING FORMAT

           An external whistle-blowing shall follow the following procedure while presenting the concern(s) in the following format:

-Background of the concerns (with relevant dates)

-Reason(s) why he/she is particularly concerned about the situation.

Disciplinary measures in line with the Staff hand book shall be taken against any Staff that receives concerns from an external Whistle blower and fails to pass same to the appropriate authority.

6.0.6 INVESTIGATING PROCESS OF CONCERN(S) BY AN EXTERNAL WHISTLE BLOWER

The Chief Internal Auditor shall within 7 days of receipt the concern from the whistle blower:

·       Acknowledge receipt of the issues(s) raised.

·       Carry out preliminary review to ascertain validity of the claim and determine whether the concerns fall within the scope of whistle-blowing or not.

·       The Compliance Officer will track the Turnaround time and provide further assurance on the investigation process, for which responsibility, still rests with Internal Audit.

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 reputation of the Centre and if possible protect all sources of evidence.

If preliminary investigation shows that the concerns fall within the whistle blowing reportable concerns, then further investigation shall be carried out. If otherwise, the Chief Audit Executive shall refer the matter to the appropriate quarters for further action. If criminal activity has taken place, the matter may be referred to the Police,with the approval of the Medical Director and where necessary, appropriate legal action taken.

The Chief Internal Auditor shall, upon conclusion of investigation, submit a detailed report to the Medical Director for appropriate actions in line with the approved policies of the Centre.

Where necessary, the Chief Audit Executive will keep the Whistle blower informed of progress and the outcome of the investigation, within the constraints of maintaining confidentiality or observing legal restrictions generally.

If dissatisfied with the outcome of the investigation, a Whistle blower may have recourse to the Medical Director which will not affxect the fundamental right of the Whistle blower to seek redress in the Court of law.

Furthermore, the Chief Audit Executive shall periodically submit a summary of reported cases and outcomes to the Medical Director or Board of Management.

The Limit of Investigation

In line with the policy of the Centre, Federal Medical Centre is committed to prompt resolution of all concerns or issues raised. If the investigation of whistle blowing complaint was not concluded promptly, the Chief Internal Auditor must keep the Medical Director abreast of progress.

7.0 PROTECTION/COMPENSATION FOR WHISTLE BLOWER (UNANIMOUS DICLOSURES)

The Centre has an obligation to adequately protect the Whistle blower, therefore, reprisal against any employee who in good faith reports a concern about illegal or unethical conduct will not be tolerated.

The Centre is also committed to maintaining confidentiality fully possible and provides assurance that all reports will be subject to appropriate investigation and conclusion though an efficient process.

Therefore, Whistle blowers are encouraged to disclose their names when filing reports to enhance credibility. However, anonymous disclosures may be considered on the following discretionary basis:

       i.           The seriousness of the issues

     ii.           The significance and credibility of the concerns

   iii.           The possibility of confirming the allegation

7.0.1 COMPENSATION

Whistleblowers either internal or external may be rewarded depending in the gravity of the case. Compensation may also be provided to Whistleblowers who may have suffered loss during the process. This is however at the discretion of management. In addition, a Whistleblower may seek further redress Ministry of Health on issues within the scope of the policy.

7.0.2 REPORTING

The Centre is also required to render quarterly reports on compliance with the provisions of the whistle-blowing guidelines along with corporate governance compliance status returns. These reports are to reach the Medical Director not later than seven days after the end of each quarter.