1.0 INTRODUCTION

A Co-operative society like other institutions is faced with situations, which call for ethical guidelines. A code of ethics specifies the ethical rules of operation in an organization. This code therefore describes the highest values to which the WAKA2CURE AND HEROES MULTIPURPOSE COOPERATIVE SOCIETY LIMITED (WAHCOMS) aspires to operate. It forms the WAHCOMS's rules of conscience.

The code of ethics outlined in this document, will serve as an ethical guideline to all the earmarked parties and will serve as a basis for the adjudication on ethical issues. It is intended to ensure that all Board/Committee members, Staff and members undertake their mandates in WAHCOMS professionally, impartially and solely and consistently in the public interest. The code elaborates standards of conduct and responsibility.

2.0 APPLICABILITY

This Code of conduct is applicable to WAHCOMS committee, staff and members. The chairman shall ensure that all committee members, staff members and the members of WAHCOMS are aware of and adhere to the prescribed Code of Conduct.

3.0 OBJECTIVES OF THE CODE

This Code of Conduct will serve the following objectives:

• To reaffirm that WAHCOMS is a business enterprise and not a welfare association.
• To facilitate achievement of corporate objectives through professional and ethical management of the business.
• To uphold and adhere to corporate governance and ethics in the manner we conduct WAHCOMS business.
• To regulate the operation and inner workings of WAHCOMS.
• To set the standard for individual and corporate behavior.
• Give guidance to all Committee members on the standards of conduct required by WAHCOMS.
• Define breaches of conduct.
• Describe the consequences of breaches of conduct.
• Explain the rights of all key stakeholders in WAHCOMS
• Outline the society's set of ethical standards of honesty, integrity and fairness.

4.0 ITEMS OF THE CODE

4.1 Conflict of Interest

• Committee members and Management staff shall not engage directly or indirectly in any business activity that competes or conflicts with WAHCOMS's interest, which, among others shall include the following:
  1. Outside financial interest:
     1. Where a committee member or staff member has a financial interest in a customer whether as a sole proprietor, shareholder, creditor or debtor, such an interest shall be disclosed immediately. Thereafter, the affected officer shall not be directly involved in WAHCOMS dealing with the members so long as the interest continues to exist.
     2. The above restriction does not apply in cases where employees are holding public quoted securities unless the management views the interest to be material, and that the financial interest is considered likely to impair the objectivity of the member or staff concerned. For the purpose of code of conduct, the holding of 5% or more of the voting share of a publicly quoted company shall be regarded as material.
  2. Other business interests — it shall be a conflict of interest if a WAHCOMS employee conducts business other than that of WAHCOMS during official working hours
  3. Other employment — No employee shall be permitted to engage in any part time employment unless with express permission of the management. Such approval shall only be granted where the interest of WAHCOMS shall not be in jeopardy.
  4. Corporate directorships — an employee shall not serve as a director of any other institution without the approval of the Committee of directors. Employees who shall hold such directorships without such approval shall seek approval immediately, if they wish to remain as directors of those institutions. However, employees may act as directors of nonprofit public services entities such as religious, educational, cultural, social welfare and philanthropic or charitable.

   

4.2 Misuse of position

• 1. Committee members and employees shall not use the name of WAHCOMS or facilities for personal advantage, be it in political or economic transactions.
  2. Committee members and employees shall not solicit or otherwise accept inducements either directly or indirectly whether in cash or in kind in order to provide any favors to a member in the provision of loans, acceptance of deposits or any other conduct of the business of WAHCOMS to which they will be entrusted jointly or individually.
  3. Confidentiality of relations and dealings between WAHCOMS and members shall be paramount. Consequently, Committee members and employees shall take precaution to protect the confidentiality of member information and transactions.
  4. Business and financial information about any member will be used or made available to third parties only with prior written consent of the member in accordance with the arrangements for the proper interchange of information between the institutions about credit risks, or when disclosure is required by law.
  5. All business dealing on behalf of WAHCOMS with current or other employees and with those who would have cause to rely upon WAHCOMS, shall be conducted fairly and equitably, Employees and Committee members shall not be influenced by friendship or association, either in meeting a members requirements, or in recommending that they be met. Such decisions shall be made on a strictly arm-length business basis. All preferential transactions with insiders or related interest shall be avoided. If transacted, such dealings will be in full compliance with the law, judged on normal business criteria basis and fully documented and duly authorized by the relevant officers of WAHCOMS.
  6. WAHCOMS will not grant or allow any unsecured advances to remain outstanding for any of its employees, officers, key members, or their associates.
  7. WAHCOMS shall not grant or allow any advance loans or credit facilities to be outstanding for any of its Committee members or individuals involved in the general management of WAHCOMS unless it is:
     1. Approved by the relevant committee of the WAHCOMS upon being satisfied that it is viable.
     2. Made in the normal course of business and on terms similar to those offered to ordinary members.
  8. WAHCOMS shall not grant advance or credit facility or give guarantee or incur any liability or enter into any contract or transaction of conduct of its business or part thereof in a fraudulent or reckless manner or otherwise than in compliance with the Cooperative Societies Act and Rules, WAHCOMS Bylaws, Loan policy, Code of Conduct and any other applicable laws.

   

4.3 Relations with Regulators and External Auditors

The Officers / members shall be duty bound to provide all relevant information to such parties, so as to create an environment of trust, confidence and goodwill between WAHCOMS and the various organs of regulators. This will be a sign of openness, one of the international cooperative values.

4.4 Policies, Rules and Procedures

All officers / members are expected to adhere to the laid down WAHCOMS policies, rules and regulations, whether express or implied.

4.5 Insider Trading /Speculative Dealing

Insider trading /speculative dealing shall not involve use of WAHCOMS resources for personal commercial transactions. No officer / member shall engage in Insider trading /speculative dealing. Such insider trading /speculative dealing may include;

• 1. Passing speculative information to a third party;
  2. Merchandising and issuing of WAHCOMS funds;
  3. Unauthorized lending of money (shy locking) using WAHCOMS funds and
  4. Any other dealing that the Committee shall determine from time to time

   

4.6 Bribes and Inducements

It is shall not be acceptable for any Officer / member to solicit any form of bribe or inducement from an existing or prospective member, counterpart, supplier or contractor or to direct anyone else to do so on one's behalf.

4.7 Professionalism

• 1. A Committee member shall;
     1. Carry out his duties in a manner that maintains public confidence in the integrity of his office.
     2. Treat the public and his fellow Committee members with courtesy and respect.
     3. Seek to improve the standards of performance and levels of professionalism in WAHCOMS based on WAHCOMS governing rules and procedures.
     4. Discharge any professional responsibilities in a professional manner.
  2. A member shall in the same spirit observe and discharge his/her responsibilities and obligations as outlined in WAHCOMS By -laws

   

4.8 Nepotism

An Officer / Member shall not practice nepotism, favoritism or such other unethical practices in the course of his/her WAHCOMS duties.

4.9 Giving of Advice

An Officer / Member who has duty to give advice shall give honest and impartial advice without fear or favor.

4.10 Misleading the members

An officer shall not knowingly give false or misleading information to members of WAHCOMS or any of the other stakeholders.

4.11 Conduct of private affairs

• 1. An Officer shall conduct private affairs in a way that maintains public confidence in the integrity of his office.
  2. An Officer shall not evade taxes.
  3. An Officer shall not neglect his financial obligations in the WAHCOMS or neglect to settle them.

   

4.12 Competence

• 1. An Officer shall exhibit excellence and proficiency in his practice and performance of his duties.
  2. He shall only undertake an assignment/responsibility commensurate with his duties.
  3. He shall not misrepresent professional qualifications, education, experience or affiliations.

   

4.13 Service Quality

• 1. An Officer shall embark on his service obligation, assignment with dedication and diligence.
  2. He shall assume ultimate responsibility for the quality and extent of service provided to individuals or groups of people.
  3. He shall not discriminate or show inhuman treatment to any person, groups on the basis of race, ethnicity, color, gender, age, marital status, political belief, mental or physical handicap, personal characteristics, conditions or status or otherwise.

   

4.14 Integrity

• 1. An Officer shall act in accordance with professional integrity and impartiality. They shall resist any external influences that interfere with the prudent running of the cooperative Society, that present a conflict of interest and/or that are contrary to the co-operative society principles.
  2. They shall not exploit or take advantage of the members socially, financially, spiritually or otherwise.
  3. All WAHCOMS officers are expected to be honest at all times.

   

4.15 Confidentiality

• 1. An Officer shall maintain confidentiality of all confidential Information, material and all other resources given to him. For the purpose of this policy, confidential information means any information which is not generally known to the public/ the society members or other institutions and belongs to the society, or learned, discovered, developed, conceived, originated or prepared during, as a result of, or in connection with ones work in the society or relating to the Committee members or other persons.
  2. In dealing with members, the Officer shall inform them fully about the limits of confidentiality in a given situation.
  3. The personal information given by members in the course of transacting business with the Society must never be divulged to third parties without their express consent, unless where withholding the information may amount to criminal offence or jeopardize life.
  4. All matters that relate to the Society's business are considered confidential and may not be discussed with outsiders or unauthorized personnel
  5. Employees must not, while in the Society's employment or at any time thereafter, without written consent of the Society, disclose to any person or persons any information concerning the affairs of the Society, the disclosure of which is, or may be, of confidential nature.
  6. Employees who in the course of their work obtain secret and confidential Society information must realize that improper or thoughtless disclosure can cause serious loss to the Society. The Society’s general conditions of employment forbid the disclosure of any such information without express permission from the relevant authorities. This condition is binding both during employment with the Society and at the time thereafter.
  7. Employees are required to report to their Head of Department any evidence of persons outside the Society showing any undue interest in or making specific inquiries.

   

4.16 Ethical Responsibility to Individuals and Groups

• 1. An Officer shall serve members with devotion, loyalty, determination and the maximum application of experience
  2. He shall not sexually harass a member of WAHCOMS or a staff member.
  3. “Sexually harass” includes “doing any of the following if the person doing it knows it is unwelcome or ought to know that it is unwelcome:
     1. Making request or exerting pressure for sexual activity of favors.
     2. Making intentional or careless physical contact that is sexual in nature and
     3. Seek to improve the standards of performance and levels of professionalism in WAHCOMS based on WAHCOMS governing rules and procedures.
     4. Making gestures, noises, jokes, comments, including innuendoes, regarding another persons's sexuality.

   

4.17 Ethical responsibility to colleagues.

An Officer shall treat his colleagues with respect, courtesy, fairness and good faith.

Consequently, he/she shall:

• 1. Co-operate with colleagues in order to promote and advance a working relationship.
  2. Not divulge confidential matters shared by other team players in the society.
  3. Maintain a good working environment, which is conducive for others to work efficiently and comfortably.
  4. Treat other colleagues with respect.
  5. Represent accurately and fairly, the qualifications, views and findings of colleagues and use appropriate channels to express opinion on these matters.
  6. At all the times act with due consideration for the interest and reputation of the Society.
  7. Extend respect to members of other Co-operative societies.

   

4.18 Ethical Responsibility to Personal Growth and Development

It is mandatory that an officer shall uphold and advance the values, ethics, knowledge and mission of his profession/assignment. Consequently he shall make it mandatory, not an expectation to;

• 1. Protect and enhance the dignity and integrity of his profession/assignment.
  2. Take action through appropriate channels against unethical conduct by other Colleagues.
  3. Critically examine and keep current with emerging issues/knowledge relevant to the Society

   

4.19 Dress Code

Dress code for staff will be as provided for in the Human resource policy of the WAHCOMS. Officers will be expected to dress in a manner befitting the occasion/event to be attended. The Board of Directors / AC shall prescribe the various dress modes for staff and for the committee for routine and non- routine occasions. This shall be revised from time to time to align to changing fashions and trends.

5.0 Other Specific Staff Code Provisions

5.1 Image

• 1. Statement of our image - We endeavor to be a leading cooperative society of choice ,in the provision of financial products and Services to our members by providing reliable savings, access to healthcare and credit services that enable them to invest, thereby improving their well being.
  2. WAHCOMS is a member-based organization and therefore the service delivered to our members by the management must reflect the statement of image of WAHCOMS.
  3. Members are the key pillars of the society and hence should be treated by all employees with utmost diligence and care that they deserve.

   

5.2 Customer Relations

Staff should accord members due attention and attend to member concerns but not promise anything they will not be able to provide on behalf of the Society. Staff should always act within their authority limits and consult whenever in doubt.

5.3 Duty

It is required that all members of staff will avail themselves for duty on normal working days, and any other time when called upon.

5.4 Visitors

• 1. Personal visitors to the work environment are discouraged. This is to avoid disrupting work and allow full concentration of the employees.
  2. All visitors shall be vetted at the entrance and required to provide details of their visit and officer to be seen.

   

5.5 Telephones

• 1. Telephones are important tools of communication for the Society. It is important that these lines should be kept open all the time. Staff members are advised to keep calls short and to focus on the business of the call.
  2. Employees are not permitted to socialize or conduct personal business using Society telephone facilities.

   

5.6 DISCIPLINARY PROCEDURE

All employees on appointment will be required to sign Official Secrets Act. Similarly, employees leaving the employment will sign the Official Secret Act. These acts will remain binding even though an employee may have left the society's employment.

6.0 Ethical Responsibility to Individuals and Groups

• 1. WAHCOMS shall intent to use every reasonable effort to prevent the occurrence of conduct not in compliance with this Code and to halt any such conduct as soon as reasonably possible after its discovery. WAHCOMS Officers and members who shall violate this Code or other WAHCOMS policies and procedures shall be subject to disciplinary action up to and including termination .WAHCOMS would if it deems fit pursue civil remedies and/or seek criminal prosecution.
  2. In instituting discipline, the following procedures shall be followed.
     1. The issue shall be dealt with at an individual level, where the person who has breached the code of conduct shall be summoned and the error shall be communicated to him/her by the relevant superior.
     2. In the event the offender does not show signs of remorse and change of behavior, the matter shall be taken to the Committee meeting for institution of discipline.
     3. Where an Officer shall be proved to have breached the code of conduct, appropriate disciplinary measures may be instituted by the Committee. In the case of the Committee ,the final decision may be referred to the General meeting while for the staff, the Committee may take any other action that may be deemed appropriate including measures in (i) above.

   

7.0 OBSERVANCE OF THE LAW

All Officers should in their course of duty strive to operate within the laws of the country and in particular with the cooperative legal framework and any other implied laws in operation in the country from time to time.

8.6 AFFIRMATION

The Code of conduct has been adopted by Committee as the official Code of conduct for Waka2cure and Heroes Multipurpose Cooperative Society (WAHCOMS).