Policy - Staff Investigation

Section: Human Resource Policies 
Policy Owner: Ignition633 Ministries Nigeria Human Resources 
Policy Name: Staff Investigation Policy  
Origination Date: November 2024

Purpose
This policy establishes a clear and consistent approach for conducting investigations into alleged misconduct, breaches of Ministry policies, or violations of laws by staff members. It aims to ensure fairness, objectivity, and transparency in workplace issues, promoting a safe, respectful, and compliant working environment. Through structured investigations, the Ministry strives to maintain integrity, uphold ethical standards, and ensure that allegations are addressed promptly and effectively.

Scope
This policy applies to all employees, contractors, and other individuals affiliated with the Ministry. It covers all types of investigations, including but not limited to allegations of misconduct, violations of company policies, and breaches of legal or regulatory standards. The policy provides guidelines for the entire investigation process, from initial reporting to resolution and corrective action, ensuring all parties understand their rights, responsibilities, and procedures.

Reporting Procedure
Initiating a Report
Any employee aware of misconduct or policy violations should report the matter immediately. Reports may be submitted to the immediate supervisor or the Human Resources Department. Anonymous reports are permitted, though identified reporting allows for follow-up and clarifications.

Confidentiality of Reports
The Ministry will treat all reports strictly, limiting disclosure to those directly involved in the investigation. However, complete confidentiality cannot be guaranteed if disclosure is necessary to conduct a fair and thorough investigation.

Non-Retaliation Clause
The Ministry prohibits retaliation against employees who report suspected violations in good faith. Any employee found retaliating against a complainant will be subject to corrective action, up to and including termination, in compliance with Nigerian Labour Law.

Investigation Process
Assignment of Investigators
Upon receiving a report, the Human Resources Department will assess the nature of the allegation and assign investigators. The assigned investigators must be impartial and have no conflict of interest or prior involvement.

Investigation Timeline
The investigation should begin promptly following the report. While the Ministry aims to complete investigations within a reasonable time frame, depending on the issue's complexity, some cases may require extended timelines.

Communication During Investigation
The involved parties will be informed of the investigation’s progress, including key milestones such as the commencement of the investigation, any interviews scheduled, and when a final decision is expected. The Ministry will strive to provide timely updates, ensuring employees are treated respectfully and sensitively during this process.

Interview Process
Investigators may interview the complainant, witnesses, and the employee under investigation to collect relevant information. Interviewees are expected to cooperate fully and provide honest and accurate information. All interview sessions will be conducted in a respectful and non-intimidating environment. Employees may request a support person or legal representative to be present during interviews, provided this is in line with Nigerian Labour Law.

Evidence Gathering
The Ministry may collect evidence, including documents, emails, and other communications, as part of the investigation. All evidence collected will be handled responsibly and securely to maintain confidentiality and integrity.

Investigating Staff Property
Conditions for Investigating Staff Property
An inspection may be conducted if there is a reasonable suspicion that evidence related to an investigation may be found on a staff member’s property, such as desks, lockers, Ministry-provided devices, or other Ministry-owned equipment. This action must be based on credible grounds, and the need for privacy will be respected in compliance with Nigerian Labour Law.

Procedure for Property Investigations
Authorization: The Human Resources Department must obtain approval from the Senior Management before inspecting any staff property.
Communication: Before any inspection, the employee involved will be informed in writing, explaining the reason for the investigation and the items or areas to be inspected.
Respect and Dignity: Inspections will be conducted respectfully, preserving the employee's dignity. An HR representative and, if requested by the employee, a support person or witness will be present to ensure transparency.
Employee Rights: Employees have the right to be present during the inspection of personal property in the workplace. The Ministry will make reasonable efforts to minimize disruptions and respect employee rights.

Handling Confidential Information
Any confidential or unrelated information that is inadvertently discovered during a property inspection will be handled with strict confidentiality. Irrelevant information will be disregarded unless it is relevant to other ongoing investigations.

Outcome and Resolution
Decision and Corrective Action
Upon concluding the investigation, the investigators will present their findings to the Human Resources Department and relevant management personnel. Decisions will be based on collected evidence consistent with Nigerian Labour Law.

Possible Disciplinary Actions
Depending on the severity of the findings, corrective actions may include verbal warnings, written warnings, suspension, or termination of employment. All actions will be proportionate, fair, and compliant with Nigerian Labour Law.

Communicating the Outcome
The Human Resources Department will respectfully communicate the investigation’s outcome to the affected employee(s), including details on any corrective actions to be taken. Feedback will be provided if necessary to prevent recurrence and promote workplace harmony.

Record-keeping and Confidentiality
Documentation
The Human Resources Department will securely store all investigation records, including reports, interview notes, and final resolutions. Access will be restricted to authorized personnel only, and records will be maintained in compliance with Nigerian Labour Law on data protection and employee privacy.

Retention Period
Investigation records will be retained for a period prescribed by the Ministry's record retention policy and Nigerian legal requirements. These records may be reviewed for any potential legal compliance or auditing needs.

Employees will be required to acknowledge their understanding of this policy as part of their onboarding process.

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This policy will be reviewed annually and is subject to change. Any changes will be communicated to all employees promptly. 

For any questions or further assistance regarding this policy, employees should contact the HR department at hr.nigeria@ignition633.org. 