NNPCL GRC Reporting PDF

2.5 Reporting, Recommendations and Closure Reporting, recommendations and closure is the final step in an investigation in which the investigation team accurately documents its findings in a manner which is free of bias. The Investigation team will only report on the factual findings from its invest...

2.5 Reporting, Recommendations and Closure Reporting, recommendations and closure is the final step in an investigation in which the investigation team accurately documents its findings in a manner which is free of bias. The Investigation team will only report on the factual findings from its investigation of cases which come to its attention and will not make any disciplinary recommendations. The Disciplinary Committee is responsible for taking disciplinary action based on the factual findings captured in the investigation report. The report of an investigation should indicate the allegations/issues investigated and should be documented to answer the following questions:  What was the incident?  Where did the incident occur?  When did the incident occur?  How did the incident occur?  Why was the incident able to occur?  Who was involved in the incident? The Investigation Team should ensure that information received during the course of an investigation is handled with utmost confidentiality and therefore should refrain from sharing any such information with personnel outside the Investigation Team or any personnel who do not require such information. Reports should be made available to individuals based on business needs only. The details of the investigation should also not be disclosed even when such investigation is closed. NNPC Limited Investigation Processes and Procedures Where there is a need to communicate the report to any external party or relevant business unit, the Investigations team should involve the legal team and Public Affairs Division (PAD) for appropriate counsel. The PAD will be responsible for making disclosures based on its counsel with the legal team and GRC. The investigation team should also ensure that the report is supported by properly referenced evidence. The following steps among others should be followed in the reporting and recommendation process of an investigation: Procedures Responsible Party Description 1. Head, Investigation Team Identify the recipients for the deliverable e.g. Ethics Committee, CEO, Board of Directors and its Audit Committee, Legal team or Disciplinary team. 2. Head, Investigation Team Select a reporting format appropriate for intended report recipients. 3. Members, Investigation Team Prepare the investigation report which should include S/N the following:  Background of the report/allegation/issue investigated  Purpose of the investigation  Procedures followed  Findings and recommendations NNPC Limited Investigation Processes and Procedures Procedures S/N 4. Responsible Party Description Head, Investigation Team Review the investigation report to ascertain if:  All information gathered and analysed during the investigation have been considered in preparing the report.  The evidence supports the conclusion  The evidence file is properly referenced  The recommendations are adequate  The sanctions recommended are appropriate (i.e. in line with the Company’s sanctions grid) If satisfactory, proceed to the next step. Otherwise, provide feedback to Investigation Team for amendment. 5. Head, Investigation Team Submit the investigation deliverable and report findings (including recommendation to address control lapses and other shortfalls identified) to the Chief Compliance Officer 6. Chief Compliance Officer Review the investigation report, evidence gathered and re-perform sample checks on the findings identified for accuracy. Amend investigation report where necessary. Update recommendations on action(s) to take in response to the findings (where necessary). NNPC Limited Investigation Processes and Procedures Procedures S/N 7. 8. Responsible Party Description Chief Compliance Officer Share details of findings and recommendations with the Chief Compliance Officer Update the investigation database with the summary of internal recipients (as identified in s/n1) for reviews and inputs the investigation findings, recommendations and status of the investigation such as completed, transferred to the police, ICPC, legal team etc. 9. 10. Chief Compliance Officer Share details of findings and recommendations with the Chief Compliance Officer Where reports are to be shared with external parties, relevant parties as required by the Standing Order for the Operation of Ethics and Compliance Units in MDAs. seek guidance from the relevant departments e.g. legal department where the report is to be shared with regulators. 11. 12. 13. Chief Compliance Officer Follow up to ensure disciplinary action is meted to erring Head, Investigation Team Collate and communicate process gaps noted during the GRC Unit Co-ordinate the remediation process to prevent a reoccurrence of the fraud incident. personnel in line with the Sanctions Grid. Investigation to the Head of Business Ethics and Chief Compliance Officer. NNPC Limited Investigation Processes and Procedures Input & Output Documents Input & Documents S/N Output Document Description Type Frequency Source Recipient Investigatio n Report Outp ut As need arises GRC GCEO, Board of Directors, Audit Committee, Ethics Committee and Disciplinary committee Detailed findings and recommen dations from the report Outp ut As need arises GRC Stakeholder of the company that reported the incident 1. 2. KPIs Key performance Indicators S/N Performance Measure Basis of Measurement Timeframe Target Latest date from the completion of the report As required 1. Timeliness for the distribution of the investigation report One week according to the time frame of the investigation 2. Compliance to the % compliance with the final As required 100% NNPC Limited Investigation Processes and Procedures Key performance Indicators S/N Performance Measure Basis of Measurement findings of the report investigation report Timeframe Target 2.5.1 Closure The following steps among others should be followed in the closure of an investigation: Procedures Responsible Party Description 1. Head, Investigation Team File the final investigation report in the investigation file created. 2. Head, Investigation Team Ensure that the investigation database is updated to indicate that the investigation has been completed or transferred to external authorities. 3. GRC Manager, Head of Business Ethics or Chief Compliance Officer based on the designated recipient of the report in the whistleblowing policy Provide an update on the outcome of the S/N investigation to the party who reported the suspicious incident where necessary. NNPC Limited Investigation Processes and Procedures Procedures S/N 4. Responsible Party Description GRC On a weekly basis, prepare a summary report of all investigations outstanding and completed in the previous week stating the following:  Date investigation started  Date investigation concluded (where necessary)  Title of the investigation  Status of the investigation (whether concluded or not) Input & Output Documents Input & Output Documents S/N 1. 2. KPIs Document Description Type Frequenc y Source Recipient Investigation file Input As required Final investigation report Head, Investigation Team Summary of outstanding investigation s Input Weekly Investigations report log GRC Function NNPC Limited Investigation Processes and Procedures Key performance Indicators S/N Performance Measure Basis Measurement of Timeframe 1. Timeliness of final investigation report log into investigation s file Latest date at which the final investigation report was issued As required Target In accordance with the timeframe of the investigation