Whistleblower Policy

Policy Statement

DgnRavePay is committed to the highest standards of integrity, transparency, and accountability in all aspects of its business. In line with our mission to build trust and protect stakeholders, this Whistleblower Policy provides a structured channel for employees, customers, partners, vendors, agents, and the public to report unethical conduct, illegal activities, financial impropriety, regulatory breaches, or violations of DgnRavePay’s policies, without fear of retaliation. This policy is in compliance with the Central Bank of Nigeria (CBN) Guidelines, the Financial Reporting Council’s Code of Corporate Governance, and applicable Nigerian laws.

Objectives

• Encourage a culture of honesty, openness, and accountability.
• Provide a safe and confidential mechanism for reporting misconduct.
• Ensure reports are taken seriously and investigated promptly, fairly, and independently.
• Protect whistleblowers against any form of retaliation, victimization, or harassment.
• Safeguard DgnRavePay’s brand, customers, and reputation.

Scope

This policy applies to:

• All employees (permanent, temporary, contract, interns).
• Board members, management, agents, consultants, and vendors.
• Customers, partners, and members of the public who interact with DgnRavePay.

Covered misconduct includes but is not limited to:

• Fraud, bribery, or corruption.
• Financial malpractice, money laundering, or terrorist financing.
• Insider trading or market abuse.
• Breach of CBN/NDIC regulations or data protection laws.
• Abuse of customer funds or misappropriation of company assets.
• Harassment, discrimination, or unethical HR practices.
• Conflict of interest, abuse of office, or gross negligence.
• Suppression, manipulation, or concealment of information.

Reporting Channels

Whistleblowers can report concerns through any of the following secure and confidential channels:

• Dedicated Email: whistleblow@DgnRavePay.com
• Confidential Web Form: help.DgnRavePay.com/whistleblow
• Telephone Hotline: +234 201 330 6189 3. (monitored independently)
• Physical Drop Box: At DgnRavePay Head Office (for anonymous written submissions).
• Whistleblowers may choose to remain anonymous. However, providing contact details may help in investigation.

Protection for Whistleblowers

• No whistleblower shall suffer retaliation, victimization, dismissal, harassment, or adverse career conse quences for reporting in good faith.
• Protection applies even if allegations turn out to be unsubstantiated, provided the report was made honestly.
• Any retaliation against a whistleblower will result in disciplinary action up to and including termination, contract suspension, or legal escalation.

Investigation Process

1. Acknowledgement : All reports will be acknowledged within 5 working days.
2. Preliminary Review: Compliance & Risk team will screen the report.
3. Investigation: Independent investigation team or external auditor (if necessary).
4. Outcome: Findings will be documented, corrective measures recommended, and sanctions applied where appropriate.
5. Feedback: Whistleblower (if identifiable) will be updated on resolution status, subject to confidentiality.

Confidentiality

• All reports will be treated with the strictest confidentiality.
• The identity of the whistleblower will only be disclosed with explicit consent, or as required by law/regulation.
• Investigation findings will be restricted to those directly involved

False or Malicious Allegations

• Whistleblowers who knowingly make false, malicious, or reckless allegations may be sub ject to disciplinary or legal action.
• However, honest mistakes or unsubstantiated reports made in good faith will not attract sanctions.

Oversight and Governance

• Board Audit & Risk Committee will provide oversight of this policy.
• The Chief Compliance Officer (CCO) will administer the process.
• Annual reports on whistleblowing cases and resolutions will be presented to the Board and, where required, to the CBN.

Policy Review

• This policy shall be reviewed annually or when re quired by regulatory updates, industry best practices, or business changes.

Commitment from Leadership

• DgnRavePay’s leadership affirms its zero tolerance stance towards unethical behavior and its absolute commitment to protecting whistleblowers, safeguarding stakeholders, and promoting a transparent financial ecosystem.