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Whistle Blowing Full Details for Aspiring Whistle Blowers

Monday, February 13, 2017

1 - What is the FMF – Whistleblowing Programme?
The Federal Ministry of Finance (FMF) whistleblowing programme is designed to encourage anyone
with information about a violation of financial regulations, mismanagement of public funds and
assets, financial malpractice, fraud and theft to report it.

2 - What is the Federal Government of Nigeria, FMF-Whistle?
The Federal Government of Nigeria, FMF-Whistle is a secure, online portal through which
information bordering on violation of financial regulations, mismanagement of public funds and
assets, financial malpractice or fraud and theft that is deemed to be in the interest of the public can
be disclosed. The online portal also permits the person disclosing the information to perform a
status check on matters that have been reported on the whistleblowing online portal.

3 - Who is a Whistleblower?
A whistleblower is a person who voluntarily discloses to the Federal Government of Nigeria, through
the Federal Ministry of Finance, a possible misconduct or violation that has occurred, is ongoing, or
is about to occur with specific concerns which are in the public interest.

4 - What type of information can be submitted?
Examples include:
o Violation of Government’s financial regulations e.g. failure to comply with the Financial
Regulations Act, Public Procurement Act and other extant laws.
o Mismanagement or misappropriation of public funds and assets (e.g. properties and
o Information on stolen public funds.
o Information on concealed public funds.
o Financial malpractice or fraud.
o Theft.
o Collecting / soliciting bribes.
o Corruption.
o Diversion of revenues.
o Underreporting of revenues.
o Conversion of funds for personal use.
o Fraudulent and unapproved payments.
o Splitting of contracts.
o Procurement fraud (kickbacks and over-invoicing etc.)
o Violation of public procurement procedures.

The programme does not apply to personal grievances concerning private contracts.

5 – How do I submit my information under the whistleblower programme?
You can submit your information through the FMF-Whistle online portal or in writing to the Federal
Ministry of Finance, Presidential Initiative on Continuous Audit Unit or by calling 09098067946.

6 - Can I submit my information to FMF-Whistle anonymously?
Yes, you can submit your information anonymously. Many individuals who may otherwise decide not
to become whistleblowers will be encouraged to provide information because they do not have to
disclose their identities while providing information.

7 - What additional information is required from a whistleblower?
If the whistleblower has evidence to support the disclosures, it is expected that the whistleblower
would submit them through the FMF-Whistle online portal. The whistleblower is expected to state
the facts with as much specific information as possible such as what occurred, who was involved and
dates of occurrence so that the allegations can be investigated.
However, it is also sufficient that the whistleblower holds a reasonable belief that the information
provided is true.
Concerns must be raised in public-spirit and in good faith, and the individual or group of individuals
must reasonably believe that the information disclosed, and any allegations contained in it, are
substantially true beyond reasonable doubt.

8 - Will my identity remain confidential?
Confidentiality will be maintained to the fullest extent possible within the limitations of the law. If
the whistleblower chooses not to disclose their identity, there will be no record of the
whistleblower’s identity. If the whistleblower chooses to disclose their identity, the identity will only
be disclosed in circumstances required by law.

9 - Who can make use of FMF - Whistleblowing online portal?
Anybody with information about a violation of financial regulations, mismanagement of public funds
and assets, financial malpractice or fraud and theft, including but not limited to: internal
stakeholders, inter-Government stakeholders, institutional stakeholders and members of the public.

10 - Will I be protected as a whistleblower?
Any Stakeholder who whistleblows in public-spirit and in good faith will be protected, regardless of
whether or not the issue raised is upheld against any Party. Any Stakeholder (internal or external)
who has made a genuine disclosure and who feels that, as a result, he or she has suffered adverse
treatment in retaliation should file a formal complaint to an independent panel of inquiry, that shall
be set-up to handle such complaint, detailing his/her adverse treatment.

If it appears that there are reasonable grounds for making the complaint, the responsibility will be
on the Party against whom the complaint of adverse treatment has been made to show that the
actions complained of were not taken in retaliation for the disclosure.
Where it is established that there is a prima facie case that a Whistleblower has suffered
adverse treatment (harassment, intimidation or victimization) for sharing his\her concerns
with the Ministry, a further investigation may be instituted and disciplinary action may be
taken against the perpetrator in accordance with the public service rules/other extant rules
and a restitution shall be made to the Whistleblower for any loss suffered.

11 - How will the information that I provided be used?
The information you provide is available immediately to the administrators of the FMFWhistleblowing
online portal or the attentioned staff, who after a preliminary analysis will
determine whether to open an investigation into the matters reported.

12 - Is the whistleblower entitled to a financial reward?
A Whistleblower responsible for providing the Government with information that directly leads to
the voluntary return of stolen or concealed public funds or assets may be entitled to anywhere
between 2.5%-5.0% of amount recovered. In order to qualify for the reward, the Whistleblower
must provide the Government with information it does not already have and could not otherwise
obtain from any other publicly available source to the Government. The actual recovery must also be
on account of the information provided by the Whistleblower.

13 - Is there protection from False or Malicious Claims?
Yes. A first level review will always be carried out to determine credibility and sufficiency of
information received. If you report false or misleading information, it will be referred to the
enforcement agents for investigation and possible prosecution.

14 - What turnaround time should I expect once the information is acknowledged?
Upon receipt of the information, an acknowledgement response will be sent and preliminary
analysis to confirm whether there is a violation or potential violation will be conducted within ten
(10) working days. If an investigation is commenced, the nature and complexity of the matters under
investigation will dictate the time frame. However, there is a feedback mechanism where a
whistleblower can independently monitor the status or progress report of tips submitted.

15 - Can I receive status updates on the progress with the information that I have provided?
When you submit a tip, the portal will generate a unique reference number. To know the status of
your submitted tip, simply click on “Get Feedback” and enter the reference number.

16 - What is the purpose or expected outcome of the programme?
o Increase exposure of financial or financial related crimes;
o Support the fight against financial crimes and corruption;
o Improved level of public confidence in public entities;
o Enhance transparency and accountability in the management of public funds;
o Improve Nigeria’s Open Government Ranking and Ease of Doing Business Indicators; and
o Recovery of public funds that can be deployed to finance Nigeria’s infrastructure deficit.

For more information on FMF-Whistle, please call 09098067946 or e-mail [email protected]

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