0700 JOHN HOLT (0700 5646 4658)

11B Ilabere Avenue, Ikoyi, Lagos

You have any question? 0700 JOHN HOLT (0700 5646 4658)

11B Ilabere Avenue, Ikoyi, Lagos

Whistle blowing

Whistle blowing


Colleagues, having come this far in restructuring and repositioning the company to its present state of profitability, we need to maintain and enhance improvements to drive the company back to its leadership position in the sectors our various businesses compete. As such, firm safeguards against the erosion of gains made must be the key interest of every stakeholder and we must work diligently to achieve and sustain this.

Therefore, it is imperative to inform you about the desire of the present Group Executive Management to reinforce whistle blowing as a means of protecting all interests. Consequently, the following guidelines are provided on effective whistle blowing to ensure prompt investigation and mitigate against any and all exposure.


  • Whistle blowing involves the reporting of unethical conduct involving or affecting our company. It is a responsibility required of every staff to sensitize Group Executive Management of actions and activities of an individual or group which are likely to expose or jeopardise the interest of John Holt Plc as an entity, financially or otherwise.
  • Effective whistle blowing is regarded as a key element of good corporate governance and good fraud risk management.
  • A key feature of effective whistle blowing is the ability of whistleblowers to report incidents anonymously and confidentially, if they so desire.

The list of infractions staff can blow the whistle on is not exhaustive. However, some examples are: 

  • Any form of fraud, theft and/or misappropriation
  • Diversion of jobs
  • Falsification of and/or unauthorised destruction of records
  • Bribery and corruption
  • Conflicts of interest
  • Breach of policies, rules or regulations of the company
  • Breach of regulatory requirements
  • Insider trading
  • Sexual harassment etc

Whistleblowers should be as clear as possible in their disclosure with documentary evidence to support where possible. Reports considered frivolous with the obvious intention to malign or cause distraction will certainly not be entertained. Therefore, it is expected that the following information be provided for effective investigation to be carried out, necessary action taken and feedback given. 

  • Nature of the incident
  • Person(s) involved in the incident
  • Witnesses to the incident
  • Date(s) of the incident
  • Place(s) of occurrence of the incident
  • Any other useful information

Generally, staff are reluctant to inform on their colleagues because of the following factors: 

  • Fear of victimization / retribution
  • Lack of trust in the system
  • Lack of anonymity and confidentiality
  • Lack of belief that appropriate actions will be taken
  • Desire to protect friends and colleagues
  • Are offenders themselves
  • Feel there is no incentive
  • Just do not care.

You are aware of the present Group Executive Management’s zero tolerance of wrong doing. This has been demonstrated in word and deed with the application of appropriate sanctions to erring staff at all levels.  Some of these penalties were applied as a result of information received from whistleblowers who were not only protected, but rewarded as required. Please rest assured that:

  • There is legal protection for the whistleblower
  • The identity of the whistleblower is NOT necessarily required
  • Even if whistleblower discloses identity, this will NOT be disclosed to anyone without the whistleblower’s consent.
  • Whistleblower can call from any phone of their choice
  • Whistleblower can hide their caller ID
  • Whistleblower can use specially created email addresses

In cases where a whistleblower chooses to remain totally anonymous, Group Executive Management will not await revelation of the identity of the whistleblower before acting on the complaint. However, there may be no opportunity for feedback either to request for more information from the whistleblower or to reward him/her as may be required. Therefore, please ensure report/complaint is clear and unambiguous.  It must contain enough details to help the investigation team make meaningful progress. 

Colleagues, this company belongs to all of us as joint stakeholders. The importance of whistle blowing cannot be over emphasised because of the following factors which each of us must consider personally: 

  • I need to protect my source of livelihood
  • Failure to report may cast doubt on my integrity and loyalty to the company
  • Silence implies that I am party to and/or in support of the misconduct
  • Silence may lead to a collapse of the company resulting in loss of jobs and other benefits, which adversely affects everybody including ME and MY family.
  • The company will not victimise me or allow me to be victimised.
  • My identity may NOT be required.
  • In cases where my identity is required, this will not be disclosed without my consent
  • There may be a reward for me.

Given the above, staff are encouraged to report infractions via e-mail, letter, text message and/or direct phone call to any of the following members of the Whistle Blowing Committee:

The Whistle blowing committee comprises the following:

  • Dr. Christopher Ezeh (Group Managing Director)
  • Mr. Adeche Okeje (Finance Director)
  • Mr. Kris Nwachukwu (Senior Executive)
  • Mrs. Titilayo Shodipe (Ag. Head Internal Audit)

The designated Telephone Hot Line for contact: 08149906885


Letter: John Holt Plc (Group Head Office), Plot 1609, Adeola Hopewell Street, Victoria Island, Lagos.

Where the complaint is against one or more members of the committee, the affected member(s) will not be part of the deliberations and decision process.

Finally, any whistleblower who is uncomfortable with dealing with the Committee, or is dissatisfied with action taken (or not taken) following whistle blown, may contact the Audit Committee Chairman, Chief Olu Akanni, via E – mail: OLUAKANNI_CO@YAHOO.COM directly with details of complaint.

I count on your continued support in our efforts to protect the source of our livelihood.

Dr. Christopher Ezeh
Group Managing Director