NIC WHISTLE-BLOWING POLICY

NATIONAL INSURANCE CORPORATION OF TANZANIA LIMITED



"WHISTLE-BLOWING" POLICY

(Making a Disclosure in the Public Interest)

Introduction

The National Insurance Corporation of Tanzania Limited is committed to the highest standards of openness, probity and accountability.

An important aspect of accountability and transparency is a mechanism to enable staff and other members of the Corporation to voice concerns in a responsible and effective manner when they discover information/acts which they believe shows serious malpractice. 

It is a fundamental term of every contract of employment that an employee will faithfully serve his or her employer and not disclose confidential information about the employer’s affairs. Nevertheless, where an individual discovers information which they believe shows serious malpractice or wrongdoing within the Corporation then this information should be disclosed internally without fear of reprisal, and there should be arrangements to enable this to be done independently of line management (although in relatively minor instances the line manager would be the appropriate person to be told).

 Consultation goes to the heart of the Corporations’ culture, and avoids an individual having to resolve a difficult ethical situation alone. Staff should in the first instance consider consulting their line manager, or Service Line Leader. If uncomfortable about raising the matter through the Corporation’s normal reporting channels or with their human resources contact, they may want to seek assistance from this whistle-blowing policy.

Our whistle-blowing policy is therefore fundamental to the Corporation’s professional integrity. In addition, it reinforces the value the Corporation places on staff to be honest and respected members of their individual professions. It provides a method of properly addressing bona-fide concerns that individuals within the Corporation might have, while also offering whistle-blower’s protection from victimization, harassment or disciplinary proceedings.

It should be emphasized that this policy is intended to assist individuals who believe they have discovered malpractice or impropriety. It is not designed to question financial or business decisions taken by the Corporation nor should it be used to reconsider any matters which have already been addressed under complaint, disciplinary or other procedures. Once the "whistle-blowing” procedures are in place, it is reasonable to expect staff to use them rather than air their complaints outside the Corporation.

Scope of Policy

This policy is designed to enable employees of the Corporation to raise concerns internally and at a high level and to disclose information which the individual believes shows malpractice or impropriety. This policy is intended to cover concerns which are in the public interest and may at least initially be investigated separately but might then lead to the invocation of other procedures e.g. disciplinary. These concerns could include

·         Financial malpractice or impropriety or fraud

·         Failure to comply with a legal obligation or Statutes

·         Dangers to Health & Safety or the environment

·         Criminal activity

·         Improper conduct or unethical behaviour

·         Attempts to conceal any of these

Safeguards

i. Protection

This policy is designed to offer protection to those employees of the Corporation who disclose such concerns provided the disclosure is made:

·         in good faith

·         In the reasonable belief of the individual making the disclosure that it tends to show malpractice or impropriety and if they make the disclosure to an appropriate person. It is important to note that no protection from internal disciplinary procedures is offered to those who choose not to use the procedure. In an extreme case malicious or wild allegations could give rise to legal action on the part of the persons complained about.

All National Insurance Corporation staff are protected from victimization, harassment, threats, coercion or disciplinary action as a result of any disclosure, where the disclosure is made in good faith and is not made maliciously or for personal gain.

ii. Confidentiality

The Corporation will treat all such disclosures in a confidential and sensitive manner. The identity of the individual making the disclosure will be kept confidential.

iii. Anonymous Allegations

This policy encourages individuals to put their name to any disclosures they make, but they are not obliged to do so.

 iv. Procedures for Making a Disclosure

·         Raising the concern

Individuals may raise a concern through various channels including:

a.    Email

b.    Letter/Mail

c.    Drop Box

d.    Telephone

e.    Direct/face to face with a responsible officer.

The whistle-blower should make it clear that they are making their disclosure within the terms of the NIC’s whistle-blowing policy. This will ensure the recipient of the disclosure realizes this and takes the necessary action to investigate the disclosure and to protect the whistle-blower's identity.

On receipt of a disclosure of malpractice, the member of management who receives and takes note of the disclosure, must pass this information as soon as is reasonably possible, to the appropriate designated responsible officer as follows:

·         Disclosure of malpractice will be investigated by the appropriate Director unless the disclosure is against the Director or is in any way related to the actions of the Director. In such cases, the disclosure should be passed to the Managing Director/Director of Internal Audit for referral.

·         In the case of a disclosure, which is any way connected with but not against the Director, the Managing Director will nominate a Senior Manager to act as the alternative investigating officer.

·         Disclosures against the Managing Director/Director of Internal Audit should be passed to the Chairman of the Board of Directors (Chairman) who will nominate an appropriate investigating officer.

·         The Whistle-blower has the right to bypass the line management structure and take their disclosure direct to the Chairman. The Chairman has the right to refer the disclosure back to management if he/she feels that the management without any conflict of interest can more appropriately investigate the disclosure.

Timescales

Due to the varied nature of these sorts of complaints, which may involve internal investigators and / or the police, it is not possible to lay down precise timescales for such investigations. The investigating officer should ensure that the investigations are undertaken as quickly as possible without affecting the quality and depth of those investigations. Besides, all investigations should be compliant with Corporation’s regulations and labour laws.

Reward

Whistle-blower rewards under the policy will range from 15% to 30% of the amounts recovered by the Corporation, depending on a number of factors.