Gateway Mortgage Bank Limited (GMB) is committed to comply with all applicable laws, rules and regulations, including those concerning accounting and auditing, and prohibits fraudulent practices by any of its board members, officers and employees.

This policy outlines a procedure for employees to report actions that an employee reasonably believes violates a law regulation or constitutes fraudulent accounting or other practices to the Bank.  The policy applies to Bank’s business and not connected to the private acts of individual business other than the bank. The Bank’s Code of Ethics and Business Conduct require the directors, officers, and employees of the bank to observe high standards of professionalism, business and personal ethics in the conduct of their duties and responsibilities.  As employees and representatives of the Bank, honesty and impeccable character must be preached while fulfilling your responsibilities.

Reporting Responsibility  

It is the responsibility of all directors, officers, and employees of the Bank to comply with the Code and to report suspected violations in accordance with this Whistleblower Policy.

No Retaliation  

No director, officer, or employee who, in good faith, reports a violation of the Code shall suffer harassment, retaliation, or adverse employment consequence.  An employee who retaliates against someone who has reported a violation in good faith is subject to discipline which may lead to termination of employment.  This Whistleblower Policy is intended to encourage and enable employees and others to raise serious concerns within the Bank rather than seeking resolution outside the Bank.

Reporting Violations  

This policy addresses the Bank’s open door administration and encourage employees ask question, make reservation, suggestions or reports with someone who can address them properly. If an employee has a reasonable belief that another employee has engaged in any action that violates any applicable law, regulation or constitutes a fraudulent practice, the employee is expected to immediately report such information to his/her supervisor to address the area of concern. However, if the employee does not feel comfortable reporting the information to the supervisor, he or she is expected to report the information to the Head, Internal Audit or Head, Human Resources Department. The senior management staff are required to report suspected violations of the policy to the Bank’s Board Audit Committee Chairman, who has specific and exclusive responsibility to investigate all reported violations.

For allegations of fraud, human rights concern or when open door policy is not feasible, individuals should contact the Bank’s Board Audit Committee Chairman directly.

Board Audit Committee Chairman  

The Bank’s Board Audit Committee Chairman is responsible for investigating and resolving all reports and allegations concerning violations of the Code and, at his/her discretion and shall advise the Managing Director/CEO and the Audit Committee. The details of the Bank’s Board Audit Committee Chairman are available on the Bank’s website- www.gatewaymortgagebankng 

Accounting and Auditing Matters  

The Board Audit Committee shall address all reported concerns or allegations regarding corporate accounting practices, internal controls, or auditing. The Board Audit Committee Chairman shall work with the Board Audit Committee members until the matter is resolved.

Acting in Good Faith  

Anyone filing a report concerning a suspected violation of the Code must be acting in good faith and have reasonable grounds for believing the information disclosed indicates a violation of the Code.  Any allegation that proves not to be substantiated and which proves to have been made maliciously or knowingly to be false will be viewed as a serious disciplinary offence.


Reports of suspected violations may be submitted on a confidential basis by the complainant, or may be submitted anonymously. Reports of suspected violations will be kept confidential to the extent possible, consistent with the need to conduct an adequate investigation.

Handling of Reported Violations  

The Management will notify the employee and acknowledge receipt of the suspected violation within fifteen (15) working days. All reports will be promptly investigated and appropriate corrective action will be taken.

The Bank will not retaliate against any employee in the terms and conditions of employment because that employee:

(a) Reports to a supervisor, Senior Management Staff, the Board of Directors what the employee believes in good faith to be a violation of the law; or

(b) Participates in good faith in any resulting investigation or proceeding, or

(c) Exercises his or her rights under any law(s) or regulation(s) to pursue a claim or take legal action to protect the employee’s rights.

The Bank may take disciplinary action (up to and including termination) against an employee who in the management’s assessment has engaged in retaliatory conduct in violation of this policy.

In addition, the Bank will not with the intent to retaliate, take any action harmful against any employee who has provided to law enforcement personnel or a court truthful information relating to the Bank or any of its employees of violating any law or regulation.