Setting the Tone at the Top with a Robust Whistleblowing Policy in Africa



Mustafa Yusuf-Adebola, ACCA
Risk Consultant

In late 2016, the Nigerian government introduced a whistleblowing policy that awarded individuals between 2.5% to 5% of the amounts recovered based on information about violations of financial regulations, mismanagement of public funds and assets, financial malpractice, fraud and theft. Within a three-month period, the government received 282 tips from whistleblowers through:

  1. Text messages (34%);
  2. Phone calls (31%);
  3. Emails (18%);
  4. A whistleblowing portal (17%).

While 55% of these tips were actionable, the medium of communication whistleblowers chose gives an indication of what Nigerians are more comfortable with.

Until recently, whistleblowing was not seen as a serious and viable detection technique in Africa. Whenever one brought up the topic, it sounded like a textbook term used only for academic purposes. Though codes of corporate governance, regulations and international affiliations forced a number of companies to have a whistleblowing policy, in the companies I reviewed I noticed what accountants call ”substance over form.” Essentially, the regulatory (or affiliate) substance of having a whistleblowing policy overrode the working form.

Regarding the tone at the top, the government’s policy has made the whistleblowing immersion and enlightenment a more engaging discourse. “I am going to blow the whistle” is now a popular phrase within the country and people use the whistle as a metaphorical expression of reporting wrongdoing.

The publicity of this policy has also spurred discussions concerning the protection of whistleblowers, rewards for whistleblowing and punishment for false reporting. Similarly, there have also been questions raised on the safeguarding of tips provided by whistleblowers to ensure they are not leaked by those who receive or work on these tips (thus making the whistleblower appear like a false informant). In response to some of these concerns, the country’s senate passed a Whistleblower Protection Bill last June.

As these discussions gain traction, organizations in the private and public sectors are now either introducing whistleblowing policies or reviewing existing ones. Recently, I have observed more Nigerian companies having a whistleblowing link on their websites while some publicize the existence of these portals on their social media pages.

Despite all of these changes, it is important that companies do not just have whistleblowing policies in place but the top hierarchy display and are seen to display a strong commitment to act ethically in order to encourage a whistleblowing culture whose “form supersedes its substance."