Introduction

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

Policy Statement

The Directors and Management of Transcorp Hotels Plc are committed to making it an acceptable practice for shareholders, employees, consultants/contractors, suppliers, 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, and consultant/contractor.

Reportable Conducts

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

Non-procedural conduct

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

Other ethics related policies or violation such as:

• Insider dealing and illegal information brokerage.
• Conflicts of interest and abuse of office, Improper business conduct.
• Misuse of physical and information assets.
• Failure to comply with any legal obligations.
• A miscarriage of justice
• Fraud, financial irregularities and all forms of bribery and corruption.
• Crime and any other unethical practice.

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

How to Raise Concern

As a first step, whistle blowers should raise concerns with their 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.

Concerns can be raised in writing via email. Written concerns should clearly outline the background and history of the issue, including names, dates, and locations where possible. To ensure confidentiality, it is recommended that the whistleblower sends the email directly to the Internal Auditor’s official email address, with the subject line clearly marked as:

“Strictly Private and Confidential – To be opened by addressee only.”

The email should not be copied to any other recipients to maintain privacy and discretion.

Whistle blowers can also raise their concerns through the dedicated e-mail address: whistleblower@transcorphotelsplc.com Whistle blowers can also call 09133624480 (from abroad + 234-09133624480) at any time

Whistle blowers do not need to sign or give their names. However, where such is done, the Internal Auditor may exercise his/her discretion on whether to proceed with the investigation from an anonymous complaint.

Safeguards and Whistleblower Protection

Transcorp Hotels 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 concern in good faith.

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

The Company will also protect the identity of any person who raises concern and does not want their names disclosed.

The Company encourages whistle blowers to put their names to allegations.

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 Transcorp Hotels’ employees, the Board, Vendors, Clients or Business Partners, and any other stakeholder who has an interest in the Company.