1. Policy Statement

Prodigy Microfinance Bank (“the Bank”) is committed to the highest standards of integrity, transparency, and ethical conduct.
This Whistleblower Policy provides a structured mechanism for employees, customers, vendors, and other stakeholders to report suspected misconduct, illegal acts, or unethical behavior without fear of retaliation.

The Bank encourages good-faith reporting and ensures that all disclosures are treated seriously, confidentially, and investigated promptly.

2. Objectives of the Policy

The objectives of this policy are to:

• Encourage early reporting of unethical or illegal conduct

• Provide clear channels for whistleblowing

• Protect whistleblowers from retaliation or victimization

• Ensure proper investigation and corrective actions

• Promote a strong culture of accountability and good governance

3. Scope of the Policy

This policy applies to:

• All employees (permanent, contract, temporary)

• Directors and management

• Customers

• Vendors, consultants, agents, and service providers

• Any other stakeholder with a relationship to the Bank

4. Reportable Matters

Whistleblowing applies to, but is not limited to, reports involving:

• Fraud, theft, or financial impropriety

• Forgery, falsification of records, or misrepresentation

• Corruption, bribery, or abuse of office

• Insider abuse or conflict of interest

• Breach of banking regulations or CBN guidelines

• Money laundering or terrorist financing

• Data breach, cybersecurity violations, or misuse of customer data

• Gross misconduct, harassment, or unethical behavior

• Deliberate concealment of any of the above

5. Whistleblowing Channels

Reports may be made through any of the following channels:

• Email: info@prodigybankng.com (recommended)

• Written Letter:
  Chief Information Security Officer
  Prodigy Microfinance Bank

• Direct Reporting:
  To the Managing Director, Chief Information Security Officer, or Board Audit Committee

• Online Reporting: www.prodigybankng.com/whistleblower-form

Reports may be made anonymously, though providing contact details may assist investigations.

6. Confidentiality & Anonymity

• All whistleblower reports will be handled with strict confidentiality

• The identity of the whistleblower will not be disclosed without consent, except where required by law

• Anonymous reports will be accepted and treated with equal seriousness

7. Protection Against Retaliation

Prodigy Microfinance Bank strictly prohibits:

• Dismissal, suspension, demotion, or intimidation

• Harassment, discrimination, or victimization

• Any form of retaliation against a whistleblower acting in good faith

Any employee found retaliating against a whistleblower will face disciplinary action, up to and including termination.

8. Whistleblower Responsibilities

Whistleblowers are expected to:

• Act in good faith

• Provide accurate and factual information

• Avoid malicious, false, or misleading allegations

Knowingly false reports may attract disciplinary or legal action.

9. Investigation Process

• All reports will be acknowledged (where contact details exist)

• Preliminary assessment will be conducted by Compliance/Internal Audit

• Independent and fair investigation will follow

• Findings will be escalated to Senior Management or the Board Audit Committee

• Appropriate corrective, disciplinary, or legal action will be taken

10. Reporting to Regulators

Where required, confirmed cases may be reported to:

• Central Bank of Nigeria (CBN)

• Nigeria Deposit Insurance Corporation (NDIC)

• Law enforcement or regulatory agencies

11. Record Keeping

• All whistleblowing cases will be properly documented

• Records will be retained in line with regulatory and data protection requirements

12. Policy Review

This policy shall be:

• Reviewed periodically

• Updated to reflect regulatory changes, operational needs, or best practices

• Approved by the Board of Directors

13. Effective Date

This Whistleblower Policy takes effect from the date of approval by the Board of Directors of Prodigy Microfinance Bank.

Approved By:

Board of Directors
Prodigy Microfinance Bank

January 2026.