Ethics, Integrity, Anti-Corruption and Whistleblowing
What the exam tests
This domain tests ethical culture, bribery and corruption controls, conflicts of interest, gifts, facilitation payments and protected whistleblowing.
Core rules
- Tone at the top matters: boards approve a code of conduct, model it, and require annual conflict declarations.
- The ICPC Act, EFCC Act and Money Laundering (Prevention and Prohibition) Act 2022 create criminal and preventive obligations. Companies also face sector-regulator integrity rules.
- Facilitation payments - small payments to speed routine action - should be prohibited; they are not a safe exception.
- A whistleblowing policy needs multiple reporting channels, confidentiality, anonymity where feasible, independent investigation, non-retaliation and audit-committee oversight.
- Gifts and hospitality require limits, disclosure and approval; a “gift” that influences a decision is a bribe.
Worked example
An employee reports a procurement manager taking a kickback. The manager learns the identity and the employee is transferred to a remote site. Reasoning: the transfer looks like retaliation. The company must protect the whistleblower, investigate independently, preserve evidence, report to the audit committee and consider external reporting. Retaliation is itself a governance failure, even if the original allegation is unproven.
Traps
Promising absolute anonymity when the investigation cannot preserve it; requiring the whistleblower to prove the case before protection; allowing “small” facilitation payments; letting the accused manager investigate; and treating a code of ethics as a document with no training or enforcement.