Lightway

Microfinance Bank Limited

4B, Sola Oguntade Close, Lekki Phase 1, Lagos.

+234 7069678000, 07071793043

info@lightwaymfb.com

www.lightwaymfb.com
RC: 7472603

WHISTLEBLOWER PROTECTION POLICY

Lightway Microfinance Bank Limited

Effective Date: August 29, 2025

1. OWNERSHIP AND CONFIDENTIALITY

This Whistleblowing Policy (“Policy”) is the property of Lightway Microfinance Bank Limited (“the Bank”) and applies to all employees, directors, contractors, third-party providers and other stakeholders of the Bank and other related entities. The content of this Policy is confidential and may not be disclosed externally without the prior written consent of the Bank.

2. PURPOSE

1. To encourage and enable the early reporting of wrongdoing, unethical behaviour or breaches of law, regulation, Bank policy or our core values.

2. To ensure all reports are received, investigated and addressed promptly and fairly.

3. To protect genuine whistleblowers from retaliation, victimisation or unfair treatment.

3. SCOPE

This Policy covers any suspected or actual:

1. Fraud, theft, embezzlement or other financial malpractice

2. Bribery, corruption or money-laundering

3. Breaches of regulatory or legal obligations (including CBN regulations)

4. Health, safety or environmental risks

5. Misuse or disclosure of confidential information

6. Bullying, harassment, discrimination or abuse

7. Any other conduct that is unethical, unlawful or contrary to Bank policy

4. DEFINITIONS

1. Whistleblower: Any person (employee, vendor, customer or third-party) who in good faith raises a concern or makes a protected disclosure.

2. Protected Disclosure: A report of wrongdoing supported by reasonable grounds and made in accordance with this Policy.

5. REPORTING CHANNELS

Whistleblowers may report concerns through any of the following secure channels:

1. Email: whistleblow@lightwaymfb.com (monitored by Compliance).

2. Phone Hotline: +2348099549011.

Reports may be made anonymously, although named disclosures usually facilitate a more thorough investigation.

6. PROTECTION AND CONFIDENTIALITY

1. All disclosures will be treated confidentially. Identities of whistleblowers will not be revealed except where required by law or with the whistleblower’s consent.

2. Retaliation, harassment, dismissal or any form of reprisal against a whistleblower is strictly prohibited. Anyone found to have retaliated will face disciplinary action, up to, and/or including termination.

3. Whistleblowers who suffer detriment may be entitled to reinstatement, compensation or other remedies as determined by the Disciplinary Committee.

7. INVESTIGATION PROCESS

1. Receipt & Acknowledgment: The Compliance Officer logs each report, acknowledges receipt within 5 business days and assigns a confidential file number.

2. Preliminary Assessment: The Head, Internal Audit and the Head, Compliance, review the report to determine whether a full investigation is warranted.

3. Investigation: If warranted, an independent Investigator (or team) is appointed. They gather evidence, interview witnesses and document findings.

4. Outcome & Action: Findings and recommendations are submitted to the Disciplinary Committee. The Committee determines corrective measures and refers serious matters to the Board or regulators as required.

5. Feedback: The whistleblower (if known) receives a summary of actions taken, subject to confidentiality and legal constraints.

8. ROLES & RESPONSIBILITIES

1. Whistleblower: Reports concerns honestly and in good faith, providing all available evidence.

2. Line Managers: Direct any whistleblowing reports they receive to Compliance immediately; do not investigate informally.

3. Compliance & Internal Audit: Ensure fair and timely handling of all reports; maintain confidentiality.

4. Disciplinary Committee: Reviews investigation reports and enforces corrective and disciplinary actions.

5. Board of Directors: Oversees the effectiveness of this Policy and receives periodic reports on whistleblowing activity.

9. REGULATORY ALIGNMENT & REVIEW

1. This Policy is developed in line with:

   • Central Bank of Nigeria (CBN) Whistleblowing Guidelines for Banks and Other Financial Institutions

   • National Pension Commission (for pension-related entities)

   • Securities and Exchange Commission standards (where applicable)

2. The Risk and Compliance Committee will review this Policy at least every three years or as needed to reflect changes in law, regulation or industry best practice.

10. COMMITMENT

By adhering to this Policy, Lightway Microfinance Bank Limited reaffirms its commitment to transparency, integrity and accountability in all aspects of its operations. All persons to whom this Policy applies are expected to familiarise themselves with its provisions and to report any wrongdoing through the designated channels.