NNPC Limited Investigation Procedures PDF

NNPC Limited Investigation Processes and Procedures without causing harm to employees. To safeguard the rights of employees, GRC and relevant function should adopt the following practices during investigations: a) Information about a fraud allegation against an employee should be kept strictly conf...

NNPC Limited Investigation Processes and Procedures without causing harm to employees. To safeguard the rights of employees, GRC and relevant function should adopt the following practices during investigations: a) Information about a fraud allegation against an employee should be kept strictly confidential and should only be shared on a business “needto-know” basis. b) The investigation team should approach the investigation with an open mind, and without any prejudice. There should be no bias or appearance of bias, i.e. the team should be impartial and also be seen to be impartial. c) Whenever it is necessary to interview alleged fraud perpetrators or witnesses who are employees, the following measures should be implemented: i. Explain the allegation or reason for the interview to the employee and allow him/her to make his defence if any (i.e. fair hearing). ii. Explain the possible outcomes of the investigation e.g. exoneration, convening of disciplinary hearing, sanctions etc. iii. Prevent harassment or intimidation of employee during the interview. There should be no interrogation of the interviewee. 2.4 Analysis of Information Subsequent to gathering information relevant to any investigation, the information should be analysed using various types of parameters in order to enable the investigation team to ascertain the veracity of the allegations being investigated. Such analysis could be financial, non-financial and visual depending on the nature of information collected and the investigation case in question. The investigation team will decide on the nature and extent of analysis to be carried out on each investigation on a case-by-case basis. NNPC Limited Investigation Processes and Procedures 2.4.1 Financial Analysis Financial analysis involves investigators reviewing relevant financial information (usually quantitative) to gain an understanding of any financial irregularities which may exist, or manipulations which may have been carried out to aid the execution of illegal or fraudulent activities. Financial analysis considers historical data, trends, and ratios which may help to identify anomalies and potential risk areas. Financial analysis techniques are useful because perpetrators of fraud are generally unable to manipulate all the information necessary to produce normal or expected financial relationships in the presence of financial fraud. 2.4.2 Non-Financial Analysis Non-financial information encompasses a wide range of information (usually qualitative) such as minutes of meetings, telephone records, emails, company records, and numerous other types of intelligence kept in the Company which may provide insight to the case being investigated. The analysis of non-financial information aids the investigation team to: a) Identify patterns and trends which help to prove or disprove a fact or assertion of the allegation. b) Link gathered information or evidence with the facts or assertions of the allegation. c) Arrive at a conclusion or hypothesis. 2.4.3 Visual Analysis Presenting data in visual formats such as charts and graphs can be used by investigators to identify irregular trends and relationships between variables. Such trends may quantitative/financial analysis. not be easily identified using only NNPC Limited Investigation Processes and Procedures 2.4.4 Escalation Matrix The investigation process is dependent on the information available to the Investigation Team. The employees are a very important source of information including documentary and oral evidence. It is therefore important that the various functions provide investigation team with the required information and support for the investigation. The following steps among others should be followed when the investigation team is not receiving the required support and or require intervention to overcome investigation challenges: Procedures Responsible Party Description Job Aid 1. Head, Investigation Team Discuss the procedures and set turnaround time for retrieval of information from various units to assist the investigation. Email or Online shared folder 2. Head, Investigation Team Create an escalation matrix to escalate matters when the investigation team is not receiving the required support and or require intervention to overcome investigation challenges. Office Tools S/N The matrix should include information on the following:     Date of request Timelines for periodic follow up Deadlines for provision of required information Individuals to receive escalation report NNPC Limited Investigation Processes and Procedures Procedures S/N 3. Responsible Party Description Job Aid Head, Investigation Team Review escalation matrix on a weekly Office Tools basis to identify items which require follow up or escalation. Input & Output Documents Input & Output Documents S/N 1. 2. KPIs Document Description Type Frequency Source Recipient Informatio n retrieval from various departmen ts Input As required Relevant departmen ts in the Company Investigation Team Escalation matrix Outp ut Weekly GRC Designated individuals to receive the report NNPC Limited Investigation Processes and Procedures Key performance Indicators S/N Performanc e Measure Basis Measurement of Timeframe Target 1. Timeliness of retrieval of information Latest date request information of of 1 week after request has been sent As required