Whistleblowing
Policy

Introduction

Sycamore promotes transparency, integrity and accountability in all its operations. This is why we have developed a Whistle Blowing policy to protect both you and Sycamore. Prospects, customers and employees are encouraged to bring to the attention of Sycamore any event, concerns, act or omission that they reasonably believe could impact negatively on the wellbeing of the company, any of its stakeholders and the general public by sending an email to info@sycamore.ng. The Company’s business provides protections and measures to individuals who make a disclosure in relation to such conduct without fear of victimization or reprisal.

1.0 Purpose

This whistleblowing policy is established to foster a culture of transparency, accountability, and ethical behavior within the organisation. We are committed to upholding the highest standards of integrity and recognize the importance of providing a mechanism for individuals to report concerns without fear of reprisal.

2.0 Scope

This policy applies to all employees, contractors, consultants, vendors, and any other individuals associated with the organisation, emphasising that adherence to ethical standards is a collective responsibility.

3.0 Definition

Reportable concerns include, but are not limited to, suspected unethical, illegal, fraud, corruption, violations of laws or regulations, financial misconduct, safety violations, environmental concerns, and unethical behavior. It is the responsibility of all individuals to report concerns promptly.

4.0 Reporting Procedures

For the avoidance of doubt, Reportable Conduct does not include personal work-related grievances. A personal work-related grievance is a grievance about any matter in relation to a staff member’s current or former employment, having implications (or tending to have implications) for that person personally and that do not have broader implications for the Company. Examples of personal work-related grievances are as follows:

  • An interpersonal conflict between the staff member and another employee;
  • A decision relating to the engagement, transfer or promotion of the staff member; A decision relating to the terms and conditions of engagement of he staff member;
  • A decision to suspend or terminate the engagement of the staff member, or otherwise to discipline the staff member.
  • Personal work-related grievances should be reported to your manager or in accordance to the Company’s Grievance Policy.

4.1 Reporting Channels

Employees are encouraged to report concerns through the following channels:

- Direct Supervisor

- Human Resources Department

- Internal Control

- Anonymously through the seamless hr whistleblowing option.

4.2 Immediate Reporting Obligation

Employees have an obligation to report concerns as soon as they become aware of potential misconduct. Delays in reporting may hinder the organisation's ability to conduct a thorough investigation.

4.3 Whistleblower Support Program

The organisation will provide a support program to whistleblowers should they choose not to report anonymously, including access to legal and counselling services, to ensure their well-being and protection during and after the reporting process.

5.0 Confidentiality and Privacy

The organization is committed to maintaining the confidentiality and privacy of whistleblowers to the fullest extent allowed by law. Anonymity will be protected unless it is essential to the investigation.

6.0 Anti-Harassment Commitment

Retaliation against whistleblowers is strictly prohibited. Any form of retaliation, including termination, demotion, harassment, or adverse employment action, will result in severe disciplinary measures.

7.0 Investigation Process

Upon receipt of a report,Sycamore will initiate a prompt and thorough investigation. The investigation will be carried out by individuals who are impartial and have appropriate expertise. Updates on the progress of the investigation will be provided to the whistleblower to the extent allowed by law and by the discretion of Sycamore as a company.

8.0 Reporting Results

Sycamore will communicate the results of the investigation to relevant stakeholders. If corrective action is required, Sycamore will take appropriate measures to address and remedy confirmed issues.

9.0 False Reports

Knowingly making false reports or providing false information in bad faith is a serious offense and may result in disciplinary action, up to and including termination.

10.0 Awareness Programs

The organization will conduct annual training programs to educate employees about the whistleblowing policy, reporting procedures, and the organization's commitment to integrity.

11.0 External Oversight

In situations where necessary, the organization will report serious concerns to external regulatory authorities in compliance with applicable laws and regulations.