Company Policies




Prepared by Chimamanda Okafor General Manager
Reviewed by Lotanna Macfoy CEO/MD
Approved by Lotanna Macfoy CEO/MD


Document History


Prepared  by Date Version Comment
Chimamanda Okafor 15/05/2021 1 Subject to review
















Whistle blowing is the act of reporting perceived or actual wrongdoing or unethical behaviour by employees, management, or other persons in an organization. The purpose of the whistle blowing program is to encourage employees to disclose any malpractice or misconduct which they observe. More so, it is important to note that employees who report allegations of malpractice will be protected as confidentiality is key to the effective implementation of a whistle blowing program.

The Whistle Blowing Policy is primarily for concerns where the interest of the company or its stakeholders is at stake. The policy is therefore fundamental to the company’s professional integrity. In addition, it reinforces the value the company places on staff to be honest and respected members of their individual professions. It provides a method of properly addressing bona fide concerns that individuals within the firm might have, while also offering whistle-blowers protection from victimization, harassment or disciplinary proceedings.

All employees are encouraged to raise genuine concerns about misconduct, malpractices and unethical behaviour at the earliest opportunity and in an appropriate way.

The company will be creating a private mail portal and a box where issues of concerns could be sent by staff who may wish to remain anonymous to assure employees of confidentiality and protection from possible reprisal.


STOILIC Group is committed to the highest standards of openness, probity, accountability and high ethical behaviour. It is committed to its core values through integrity and ethical behaviour by ensuring that it maintains an environment where employees and other stakeholders can act appropriately, without any fear of retaliation. The policy is to help support and encourage employees and/or stakeholders to report and disclose improper and/or illegal activities. STOILIC Group is committed to investigate promptly any reported misconduct and to protect those who come forward to report such activities. It further assures that all reports shall be treated in strict confidence. The Company’s operating procedures are intended to detect and prevent or deter improper activities taking cognisance that even the best systems of controls may not provide absolute safeguards against irregularities. This policy is intended to enable the Company to investigate and take appropriate action against any reported misconduct or concern. This will demonstrate that employees take their responsibilities seriously and helps to avoid the negative publicity that often accompanies disclosures to external parties. Thus, the Board of Directors and Management is committed towards promoting a culture of openness, accountability and integrity, and will not tolerate any harassment, victimization or discrimination of the whistle-blower provided such disclosure is made in good faith with reasonable belief that what is being reported is factual.


This policy and procedure manual is intended to encourage staff and other relevant stakeholders to report perceived unethical or illegal conduct of employees, management, directors and other stakeholders to appropriate authorities in a confidential manner without any fear of harassment , intimidation, victimization or reprisal of anyone for raising concern(s) under this policy. Specific objectives of the policy are:

  • To provide support to all employees who have a concern to raise;
  • To encourage all improper, unethical or inappropriate behaviour to be identified and challenged at all levels of the organization;
  • To provide clear procedures for reporting and handling such concern(s);
  • To proactively prevent and deter misconduct which could impact the financial performance and expose the Company to reputational risk;
  • To provide assurance that all disclosures will be handled seriously, treated as confidential and managed without fear of reprisal of any form; and
  • To help promote and develop a culture of openness, accountability and integrity.


STOILIC Group whistle bowing policy applies to all employees of STOILIC Group, its subsidiaries and any other person who provides service to the company including contractors, consultants, vendors, etc.


What is a concern? A concern includes a grievance or report of a suspected breach of law or group policy.
Am I obliged to report a concern? If you have a concern such that you reasonably believe that there is a breach of law or any group policy, you are required to report it.

Will I be disadvantaged?



No- you will not be disadvantaged for reporting a concern under the policy regardless of the outcome, provided you make the report in good faith.

Each person who reports a concern under this policy is expected to act in good faith. In making a report under this policy, the matter will be treated sternly, and the employee may be disciplined accordingly (for example, in the case of an unfounded malicious allegation).

Anyone who reports a concern but is later found to have been involved in any wrongdoing will not be protected in relation to their role in that wrongdoing (although in some cases the making of a report may be a mitigating factor).

What happens after I report a concern? All concerns reported under this policy will be taken seriously. The way a matter is handled will depend on the type of concern raised.
Will I get any feedback? Generally, you will be given feedback, subject to any privacy, confidentiality or other legal considerations.
How do I report a concern?

You can report a concern either by calling the Whistle blowing Ethics Facilities provided by the company. These are:

Telephone numbers:




Boxes to be placed at designated areas.

You can report a concern either by disclosing your identity or remaining anonymous. If you want your identity to be disclosed, then you need to give a written consent to that effect.



Employees and other stakeholders can raise concerns encountered in the workplace relating to a perceived wrongdoing. The company considers such wrongdoing to include:

  • Fraud, which means any act or omission, including a misrepresentation, that knowingly and recklessly misleads, or attempts to mislead, a party to obtain financial or other benefit or to avoid an obligation;       
  • Corruption, which means the offering, giving, receiving or soliciting, directly or indirectly, anything of value to influence improperly the actions of another party;
  • Misconduct, which means failure by the company’s personnel to observe the company’s codes of conduct;
  • Coercive practices, which mean impairing or harming, or threatening to impair or harm, directly or indirectly, any party or the property of the party to influence the actions of another party;
  • Collusive practices, which mean arrangement between two or more parties designed to achieve an improper purpose, including influencing improperly the actions of another party;
  • Money laundering and financing of terrorism;
  • Cases of bullying, physical/sexual harassment and those concerning dignity at work;
  • General malpractice such as immoral, illegal or unethical conduct (including where someone’s health & safety has been put in danger); and
  • Any other activity which undermines the company’s operations and corporate philosophy.



The company’s Ethics line facilities that will be made available to the employees are telephone lines, boxes placed at designated areas and email address. The telephone lines will be manned between 8:00am and 5:00am on workdays only. While the fax number and email address will always be available except during period of maintenance.

Telephone calls might be recorded, and information is transcribed into a call sheet memo for transmission to the Management. STOILIC Group officers, staff, representatives or agents shall not be entitled to have access to such tape recordings, or email messages received from whistle blowers. These measures are necessary in order to maintain confidentiality and anonymity of the whistle blowers.


Any staff member who reports an irregularity, if this is done in good faith and in compliance with the provisions of this policy, shall be protected against any acts of retaliation.

For the purposes of this policy, “retaliation” is defined as any action or threat of action which is unjustly detrimental to the whistle blower because of his /her report. Including, but not limited to harassment, discrimination and acts of vindictiveness, direct or indirect, that are recommended, threatened or taken against the whistle blower.

“Good faith” can be taken to mean the explicit belief in the authenticity of the reported incidents, i.e. the fact that the member of staff reasonably believes the transmitted information to be true.


After incident reports are received from the whistle bowing committee, a preliminary evaluation will be carried out by compliance unit to validate the incidents. Cases that require further investigations will be forwarded to internal Audit unit. Where the committee wants information on an outcome of investigation, such information should be given as it is important for the whistle blower to be aware that an action is being taken about the incident report.

Where there is no case to a claim raised by a Whistle-blower, but the company staff making such claim acted in good faith, the Head of Internal Audit shall ensure that such staff suffers no reprisal. However, when a member of staff makes a report in bad faith, particularly if it is based knowingly on false or misleading information, the staff shall not be protected and shall be subject to disciplinary measures.



Any STOILIC Group member of staff implicated by reports of irregularities must be notified in good time of the allegations made against them, provided that this notification does not impede the progress of the procedure for establishing the circumstances of the case.

It is important to note here that the basic rights of any member of staff implicated by the reported incidents must be respected, whilst ensuring that the procedures are effective.


The ED Compliance shall be consulted in advance in the event of the adoption or amendment of any internal provision establishing obligations for members of staff of the company or its stakeholders to report irregularities.

The ED Compliance in agreement with the Group Head, Human Resources shall propose to Executive Management Committee any necessary amendments to these provisions.


CSR is the act of integrating business operations and values, whereby the interest of all stakeholders including investors, customers, employees, the community and the environment are reflected in the company’s policies and actions.

Commitment and Aims

STOILIC Group is committed to:

  • Continuous improvement in our Corporate and Social Responsibility (CSR) strategy by;
    • Encouraging our business partners to implement CSR
    • Continually improving our performance and meeting all applicable legislation
    • Informing our staff to be mindful of the effect of their actions on non-renewable resources.
    • Introducing procedures to assist with implementing CSR.
  • This CSR policy is to make clear to all stakeholders what STOILIC means by CSR and how we propose to work towards implementing and achieving CSR. The CSR policy applies throughout all activities of the company.
  • We recognise that CSR embraces all aspects of sustainable development and social issues which are of most relevance to STOILIC and decide at what stage this CSR policy could most effectively and legally be included;
  • We shall operate in a way that safeguards against unfair business practices;
  • We believe that a responsible approach to developing relationships between companies and communities they serve, national and international, is a vital part of delivering business success;
  • When carrying out our business, STOILIC will determine the environmental, social and economic issues;
  • STOILIC will continually review all policies and business practices to encourage engagement with business partners and to promote development.

Corporate Governance

  • We are committed to ensuring that our business is conducted in all respects according to rigorous ethical, professional and legal standards;
  • All the laws that regulate and apply will be complied with;
  • STOILIC endeavours to ensure that stakeholders have confidence in the decision-making and management processes of the service provided, by the conduct and professionalism of all staff. We do this by continually training and developing our staff;
  • All groups and individuals with whom we have a business relationship will be treated in a fair, open and respectful manner;
  • Competition will be reasonable and based upon the quality, value and integrity of the services being supplied;
  • Feedback on performance will be actively sought, and we will encourage customers to give feedback on our performance and ensure that all customer comments are analysed, responded to and where appropriate, acted upon;
  • Action Plan will be developed to ensure continuous improvement is achieved.


Protection of the environment in which we live and operate is part of STOILICs values and principles and we consider it to be sound business practice. Care for the environment is one of our key responsibilities and an important part of the way in which we do business. We strive to reduce our energy use, manage our carbon footprint and decrease our overall environmental impact.

We commit our company to:

  • Comply with all relevant environmental legislation, regulations and approved codes of practice
  • Protect the environment by striving to prevent and minimize our contribution to pollution of land, air, and water
  • Seek to keep waste to a minimum and maximize the efficient use of materials and resources
  • Manage and dispose of all waste in a responsible manner
  • Provide training for our staff so that we all work in accordance with this policy statement and within an environmentally aware culture
  • Regularly communicate our environmental performance to our employees and other significant stakeholders
  • Develop our management processes to ensure that environmental factors are considered during planning and implementation
  • Monitor and continuously improve our environmental performance.

Human Rights

STOILIC strives to foster safe, respectful, and inclusive workplaces. STOILIC culture is committed to respect, integrity, service and excellence. This commitment applies to all of our employees and spans our efforts to develop a diverse workforce, maintain safe and secure workplaces, and support the health, wellness and career development of our employee base. We define these values to hiring; workplace behaviour; and employee conduct toward each other, our clients, and our business partners.

Humane Treatment

There is zero tolerance for harsh or inhumane treatment including sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of employees; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these requirements are clearly defined and communicated to employees.

Harassment Prevention and Non-Discrimination

Unlawful harassment, in any form and regardless of intent, is a form of discrimination and interferes with our commitment to equal employment opportunity. STOILIC does not engage in discrimination based on race, colour, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership, or any other category protected by law. Harassment and/or discrimination contradict our values and have no place at STOILIC. Our Employee Handbook clearly addresses our policies and disciplinary action regarding harassment.

The policy: Defines harassment (including sexual) and provides examples of prohibited activities. Describes our expectations of all employees, including complaint procedures, and the special responsibilities of managers. Uses the recommendations of experts and follows the best practices of top companies relative to integrity standards. If allegations of harassment or discrimination occur, our Human Resources team acts swiftly to uncover and evaluate facts, take remedial action if warranted, and eliminate root causes of the problematic behaviour.

Open Communication & Freedom of Association

Open communication and direct engagement between employees and management are the most effective ways to resolve workplace and compensation issues. Our company has an open-door policy that allows employees to communicate discreetly and openly with all levels of management. We expect and encourage employees throughout our business operations to make STOILIC principles and practices a part of their everyday work and hold our employees accountable for adhering to our Conduct and Work Rules Policy in our Employee Handbook.


  • A Sustainable Policy for Procurement of services will be maintained that will set out the principles, policies and procedures within Company.


Our company preserve a budget to make monetary donations to advance education and community events. In addition, donations to alleviate those in need.

We will actively invest in R&D. We will be open to suggestions and listen carefully to ideas. Our company will try to continuously improve the way it operates.

Our company is committed to the United Nations Global Compact. We’ll readily act to promote our identity as a socially aware and responsible business. Management must communicate this policy on all levels. Managers are also responsible for resolving any CSR issues.

STOILIC Group is committed to safeguarding human health and safety and conserving the environment as an integral part of its business. Meeting this commitment is essential to the company’s long-term success and is achieved in all working projects by implementing this HSE Policy through the following measures:

  • Communicating the Health, Safety & Environmental (HSE) Policy to all employees for them to be aware of their individual Health, Safety & Environmental obligations and responsibilities;
  • Providing appropriate training, supervision, information and resources to all employees to enable HSE objectives to be achieved;
  • Setting HSE objectives, responsibilities and accountability for HSE performance, with measurement and reporting requirements;
  • Establishing methods for identifying and assessing hazards and reducing risks to levels as low as are practicable;
  • Complying with relevant local and international HSE legislations, regulations, legal and Contracts’ requirements, and applying responsible standards where these do not exist;
  • Promoting commitment to HSE Management System’s continual improvement;
  • Establishing a culture of prevention of accidents and hazards throughout projects managed by STOILIC Group, and influence prevention of pollution and reduction in consumption of resources;
  • Using energy and natural resources efficiently and reducing waste and emissions;
  • Reviewing HSE objectives and targets through periodic management reviews;
  • Undertaking appropriate reviews and evaluations of its activities and services to measure progress and drive continuous improvement.

All STOILIC Group personnel are responsible for implementing the Health, Safety and Environmental measures necessary for the well-being of all persons at work.

All levels of management and employees are expected to participate in and comply with HSE initiatives and exercise individual responsibility for their own safety, the safety of others, and protection of the environment.

On Projects where HSE Management is STOILICs responsibility, STOILIC will take the necessary controls and measures to monitor the Contractors’ adherence to all relevant and applicable local and international HSE standards, provisions and policies as applicable to each project and STOILIC’s scope of services.

All STOILIC Group employees shall observe, implement and give their full support to this HSE policy

Lotanna Macfoy                                                              
President and CEO
May 2021


The purpose of this policy is to outline STOILIC Group’s commitment to the provision of professional services and products to meet and where possible, exceed our customers’ requirements and expectations, thereby assisting them to achieve their strategic objectives.

Quality Management System

is defined as all the things we do to deliver our services/products to meet and where possible, exceed our customers’ requirements and expectations.

We are committed to continuous improvement and have established a Quality Management System which provides a framework for measuring and improving our performance.

We have the following systems and procedures in place to support us in our aim of total customer satisfaction and continuous improvement throughout our business;

  • Building genuine partnerships with our customers to ensure our joint success into the future
  • Using safe systems of work that are environmentally sustainable and supported by documented and auditable standards, procedures, software and records
  • Regular gathering and monitoring of customer feedback
  • A customer complaints procedure
  • Selection and performance monitoring of suppliers against set criteria
  • Provide ongoing competency-based training for our employees and management to ensure strong professional ethics and a customer-focused work force
  • Encourage team problem-solving at all levels of STOILIC Group to implement work practices and processes that improve the service level and/or our management and business systems
  • Regular audit of our internal processes
  • Measure, monitor, review and wherever possible continually improve our management and business systems and associated key processes through the development of specific departmental and individual KPIs and other business objectives
  • Measurable quality objectives which reflect our business aims
  • Management reviews of audit results, customer feedback and complaints

Our internal procedures are reviewed regularly and are held in a Quality Manual which is made available to all employees.

This policy is posted on the company Notice Board and can also be found in the staff handbook.

Although the Managing Director has ultimate responsibility for Quality, all employees have a responsibility within their areas of work to help ensure that Quality is embedded within the whole of the company.

Consequence for Non-Compliance or Breaches

Breaches of the Quality Management Systems Policy will be investigated which could result in disciplinary action being taken including termination of employment or contract.

CEO Sign off Developed by Quality Management
Issue Date May 2019
Responsibility for Review Quality Management
Review date May 2021