The typical global organization with operations in Nigeria offers a well-resourced and technically functional hotline for employees to make internal reports about wrongdoing. Trouble is, the country’s laws don’t yet protect such individuals from retaliation. Legal and governance researcher Obongodu Paul Unanam explores what this important distinction means for Western companies operating in the country.
Most multinationals deploy internal reporting infrastructure as a uniform global system. A hotline number, a web portal, perhaps a third-party vendor and a policy document that promises confidentiality and no retaliation. The assumption behind this architecture is that the legal environment in each country creates roughly the same conditions for it to function. In the US, the UK and South Africa, that assumption may be defensible. In Nigeria, it is not.
This doesn’t show up in your program on paper. Your Nigerian subsidiary will have the hotline number, and your Nigerian employees will technically be able to access it. What the program cannot replicate is the legal backstop that makes using it a rational act for someone who has witnessed serious wrongdoing.
One reason for that is there is no statutory whistleblower protection law in Nigeria. The government launched a whistleblowing policy in December 2016 that offered financial rewards of 2.5% to 5% of recovered funds for tips leading to asset recovery, but it created no legal protection against retaliation. It is a policy...
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