Internal Investigation Procedure Template for Nigeria

An Internal Investigation Procedure guides organizations through the steps of examining workplace issues, misconduct, or violations fairly and thoroughly. In Nigeria, these procedures help companies comply with the Corporate Affairs Commission's governance requirements and protect themselves under the Companies and Allied Matters Act (CAMA).

The procedure outlines key steps like gathering evidence, interviewing witnesses, documenting findings, and recommending actions while maintaining confidentiality. Good procedures also incorporate local labor laws and help organizations address issues early, from fraud allegations to ethical concerns, before they escalate into regulatory problems or legal disputes.

Start using an Internal Investigation Procedure immediately when employees report misconduct, fraud, or ethical violations in your Nigerian organization. Common triggers include missing funds, harassment complaints, conflicts of interest, or violations of company policies and regulatory requirements under CAMA.

The procedure becomes essential during whistleblower reports, suspected breaches of the Nigerian Code of Corporate Governance, or when external regulators like the Corporate Affairs Commission demand answers. Having this process ready helps protect your organization's interests, ensures fair handling of sensitive issues, and demonstrates commitment to proper governance standards.

• Internal Investigation Procedures in Nigeria typically come in three main forms: Basic Misconduct Procedures for general workplace issues, Financial Investigation Procedures focusing on fraud and accounting irregularities, and Regulatory Compliance Procedures tailored to meet Corporate Affairs Commission requirements
• Industry-specific variations exist for banking, oil and gas, and telecommunications sectors, each incorporating unique regulatory requirements and reporting protocols
• Organizations also differentiate between confidential procedures for sensitive matters like executive misconduct and standard procedures for routine operational issues

• Human Resources Directors: Lead the development and implementation of Internal Investigation Procedures, ensuring compliance with Nigerian labor laws
• Legal Counsel: Reviews and approves procedures, provides guidance on legal requirements, and ensures alignment with CAMA regulations
• Compliance Officers: Oversee investigations, maintain documentation, and ensure adherence to corporate governance standards
• Department Managers: Participate in investigations, provide relevant information, and help implement recommended actions
• External Auditors: Review investigation procedures during audits and assess their effectiveness in preventing misconduct

• Company Policies: Review existing policies, codes of conduct, and disciplinary procedures to ensure alignment
• Legal Framework: Check CAMA requirements, Nigerian labor laws, and industry-specific regulations affecting investigations
• Reporting Channels: Define clear methods for employees to report concerns confidentially
• Investigation Team: Identify key personnel responsible for conducting investigations and their specific roles
• Documentation Standards: Establish templates for recording evidence, interviews, and findings
• Timeline Guidelines: Set realistic timeframes for each investigation phase while maintaining flexibility

• Scope and Purpose: Clear definition of what triggers an investigation and covered behaviors under Nigerian law
• Confidentiality Provisions: Requirements for handling sensitive information and protecting whistleblowers
• Investigation Protocol: Step-by-step process aligned with CAMA and Corporate Affairs Commission guidelines
• Documentation Requirements: Standards for recording evidence and maintaining investigation records
• Rights and Responsibilities: Clear outline of all parties' roles, including accused persons' right to fair hearing
• Reporting Mechanisms: Procedures for submitting findings to management and relevant regulatory bodies

Internal Investigation Procedures are often confused with Disciplinary Procedure, but they serve distinct purposes in Nigerian organizations. While both deal with workplace misconduct, their scope and timing differ significantly.

• Purpose and Timing: Internal Investigation Procedures focus on fact-finding and evidence gathering before any conclusions are drawn. Disciplinary Procedures come into play after misconduct is confirmed and outline specific consequences
• Legal Framework: Investigation procedures align with CAMA's corporate governance requirements for fair inquiry, while disciplinary procedures must comply with Nigerian labor laws on employee rights
• Scope of Application: Investigation procedures cover a broader range of issues including fraud, ethical violations, and regulatory concerns. Disciplinary procedures specifically address employee misconduct and its consequences
• Documentation Requirements: Investigation procedures emphasize evidence collection and witness statements, while disciplinary procedures focus on formal warnings, hearing records, and appeal processes