Whistleblowing Policy

1. Introduction

The Amaefule and Astudillo Empowerment Foundation (T.A.A.E Foundation) is committed to the highest standards of honesty, integrity, accountability, and ethical conduct in everything it does. We serve vulnerable communities, children, and persons with disabilities, and we hold ourselves to a standard of transparency that those communities deserve.

There may be occasions when a trustee, staff member, volunteer, partner, beneficiary, or member of the public becomes aware of conduct within the Foundation that is illegal, unethical, unsafe, or contrary to our policies. This policy exists to give every person a safe, protected, and confidential channel through which to raise those concerns.

This policy is a mandatory requirement under the Nigeria Not-For-Profit Governance Code (NFPGC) 2023, which requires every non-profit organisation to establish a whistleblowing policy that encourages individuals to report credible information on illegal or unethical practices, breaches of laws and regulations, and violations of organisational policies. This policy fulfils that obligation.

2. Purpose of This Policy

The purpose of this policy is to:

• Provide a clear, safe, and accessible mechanism for raising concerns about wrongdoing within or connected to the Foundation
• Guarantee that every person who raises a concern in good faith is fully protected from retaliation, victimisation, and adverse consequences
• Guarantee the anonymity of whistleblowers who wish to remain anonymous
• Ensure that all concerns raised are taken seriously, investigated fairly, and resolved appropriately
• Fulfil the Foundation's obligations under the NFPGC 2023
• Reinforce a culture of openness, accountability, and integrity across the organisation

3. Scope of This Policy

This policy applies to any person who raises a concern about the Foundation, including:

• Board members and trustees
• The Chief Executive Officer and executive leadership
• Staff members
• Volunteers, whether paid or unpaid
• Consultants and contractors
• Interns and community mobilisers
• Partner organisations and their representatives
• Beneficiaries and community members
• Members of the general public

A concern may be raised about any conduct within the Foundation or connected to its activities, including conduct by any of the persons listed above.

4. What Is Whistleblowing

Whistleblowing means raising a concern, in good faith, about conduct that you genuinely believe to be wrong. It is different from making a personal complaint about your own treatment, which is handled through a separate grievance process.

A whistleblowing concern is one that relates to the Foundation as a whole or to the conduct of a person acting on behalf of the Foundation, rather than a concern that affects only the individual raising it.

5. Protection for Whistleblowers

The Foundation unconditionally guarantees the following protections to every person who raises a concern under this policy:

Protection from Retaliation

No person who raises a concern in good faith shall be dismissed, demoted, disciplined, harassed, victimised, excluded, disadvantaged, or treated in any adverse manner as a result of making a disclosure. Retaliation against a whistleblower is a serious disciplinary offence that will result in action against the person responsible, up to and including termination and referral to the relevant authorities.

Anonymity

Any person who raises a concern may choose to remain anonymous. The Foundation will accept anonymous reports and will investigate them to the best of its ability given the information provided. The identity of a whistleblower who does provide their name will not be disclosed without their explicit consent, except where the Foundation is legally required to do so.

Good Faith Protection

This policy protects persons who raise concerns honestly and in good faith, even if the concern turns out, upon investigation, to be unfounded. The test is whether the person raising the concern genuinely believed at the time that the information disclosed was true and that it was in the public interest to disclose it. Malicious, false, or vexatious disclosures made with the deliberate intent to harm another person are not protected under this policy and may be subject to disciplinary action.

No Obligation to Prove

A person raising a concern is not required to investigate the matter themselves or to provide conclusive proof before reporting. It is sufficient to have a genuine and reasonable suspicion. The Foundation's responsibility is to investigate, not the responsibility of the person raising the concern.

6. How to Raise a Concern

Any person wishing to raise a concern may do so through any of the following channels. You may choose whichever channel you feel most comfortable with, and you may choose to remain anonymous in any of them.

Primary Reporting Channel

Concerns should in the first instance be submitted in writing to:

Where the Concern Involves the CEO

If the concern relates to the conduct of the Chief Executive Officer, it should be submitted directly to the Board Chairperson. This ensures that the CEO is not involved in the initial handling of a concern about their own conduct.

Where the Concern Involves the Board Chairperson

If the concern relates to the conduct of the Board Chairperson, it should be submitted to another trustee or to the full Board, clearly marked as a whistleblowing concern for independent handling.

Where the Concern Involves All Internal Leadership

In exceptional circumstances where the concern involves the entire leadership of the Foundation and the reporter does not feel that any internal channel is safe, the concern may be reported externally to the Corporate Affairs Commission (CAC), the Economic and Financial Crimes Commission (EFCC), or another relevant regulatory body. The Foundation supports and respects the right of any person to make such an external report.

Verbal Reports

Where a person is unable to submit a written report, a verbal report may be made directly to the Board Chairperson. The recipient of a verbal report shall document the concern in writing immediately, read the written record back to the reporter for accuracy, and obtain the reporter's acknowledgement where possible.

7. What Happens After a Concern Is Raised

Acknowledgement

The Foundation will acknowledge receipt of every concern within five working days of receiving it, except where the report is anonymous and no contact details have been provided.

Initial Assessment

Upon receipt, the Board Chairperson or designated independent trustee will conduct an initial assessment to determine the nature and seriousness of the concern, whether an immediate protective or interim measure is needed, and the most appropriate way to investigate.

Investigation

All concerns will be investigated promptly, thoroughly, and fairly. The investigation will be conducted by a person who is independent of the subject of the concern. Where the concern is of a serious nature, the Board may appoint an independent external investigator.

The person who is the subject of a concern will be informed of the allegation at the appropriate stage of the investigation and will be given a fair opportunity to respond, unless doing so would compromise the safety of the reporter or the integrity of the investigation.

Outcome

At the conclusion of the investigation, the Foundation will, where possible, inform the person who raised the concern of the outcome. The level of detail provided will depend on confidentiality considerations and the nature of the matter. Where the concern is substantiated, appropriate action will be taken. This may include disciplinary action, referral to the relevant authorities, changes to policies or procedures, or other corrective measures.

Timeframes

The Foundation will endeavour to complete investigations within a reasonable timeframe. For straightforward matters, this will typically be within four weeks of the concern being received. For more complex matters, the reporter will be kept informed of progress.

8. Record Keeping and Confidentiality

All whistleblowing reports and investigation records will be maintained securely and confidentially. Access will be restricted to those directly involved in handling the concern.

Records of concerns raised, investigations conducted, and outcomes reached will be retained for a minimum of seven years. These records will be available to the Board for governance and oversight purposes and may be disclosed to regulatory authorities if required.

The Foundation will never disclose the identity of a whistleblower without their consent, except where it is legally compelled to do so. In such circumstances, the Foundation will inform the whistleblower in advance wherever possible.

9. Responsibilities

Board of Trustees

The Board bears ultimate responsibility for ensuring that this policy is in place, communicated, and implemented effectively. The Board shall receive an annual summary of whistleblowing activity, including the number of concerns received, the nature of those concerns, and the outcomes of investigations. This reporting requirement is consistent with the governance obligations of the NFPGC 2023.

Board Chairperson

The Board Chairperson is the primary recipient of whistleblowing concerns and is responsible for ensuring that every concern is assessed, investigated, and resolved appropriately. The Board Chairperson is also responsible for ensuring that no whistleblower suffers retaliation.

Chief Executive Officer

The CEO is responsible for promoting awareness of this policy among all staff and volunteers, and for ensuring that the Foundation's culture actively encourages people to speak up. The CEO has no role in handling concerns that relate to their own conduct.

All Staff and Volunteers

Every person connected to the Foundation has a responsibility to raise concerns when they genuinely believe that something is wrong. Silence in the face of genuine wrongdoing is not acceptable. Every person also has a responsibility to cooperate fully and honestly with any investigation conducted under this policy.

10. Awareness and Communication

The Foundation will ensure that this policy is communicated clearly to all trustees, staff, volunteers, and partners. It will be made available on the Foundation's website and will be provided to all new trustees, staff, and volunteers as part of their induction.

The Foundation will periodically remind all connected persons of the existence of this policy and the protections it provides. A culture of speaking up begins with leadership, and the Board and CEO commit to modelling the openness and integrity that this policy reflects.

11. Relationship With Other Policies

This Whistleblowing Policy operates alongside, and should be read together with, the following Foundation policies:

• Safeguarding Policy — for concerns about abuse, exploitation, or harm to beneficiaries
• Financial Management Policy — for concerns about financial misconduct or misuse of funds
• Anti-Fraud and Anti-Corruption Policy — for concerns about fraud, bribery, or corruption
• Conflict of Interest Policy — for concerns about undisclosed personal interests

Where a concern falls under the Safeguarding Policy, it should be reported through both channels simultaneously. The safety of any person at risk must always be the immediate priority.

12. Policy Review

This policy will be reviewed annually by the Board of Trustees. An earlier review may be triggered by a significant whistleblowing event, changes in Nigerian law or the NFPGC, or feedback indicating that the policy is not functioning as intended.

The Foundation is committed to continuously improving its whistleblowing arrangements to ensure they remain effective, accessible, and trusted.

13. Declaration and Adoption

This Whistleblowing Policy has been formally adopted by the Board of Trustees of the Amaefule and Astudillo Empowerment Foundation. It reflects the Foundation's unwavering commitment to integrity, transparency, and the protection of every person who has the courage to speak up.

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You do not need to use your real name or email address if you wish to remain anonymous. A concern raised anonymously will still be taken seriously and investigated.