Code of Business Integrity

with Nigerian Laws supplementary section

As part of PAAN’s (“the Company”) compliance culture, we have adopted a Code of Business Integrity. This code sets out the principles and behavior we must all follow in order to build and maintain an ethical culture throughout the organization. We must demonstrate integrity in our conduct, dealings with fellow employees, customers, intermediaries, suppliers, governments and treatment of company property. Our business integrity policy is a guideline to:

  1. Promote honest and ethical conduct — PAAN’s policy is that all employees maintain the highest ethical standards
  2. Maintain a workplace in which the integrity and dignity of each individual is valued — All employees have a right to work in an environment that is free of unlawful discrimination and harassment.
  3. Assure compliance with laws, rules and regulations — All employees must comply with all applicable laws and regulations when conducting Company business
  4. Assure the proper use of the company’s assets
    1. Employees should protect Company assets and ensure their efficient use. Company assets must be used only for legitimate business purposes. Company property shall not be sold, loaned or given away regardless of condition or value, without proper authorization.
    2. Any business, financial or other relationship with suppliers, customers or competitors that might influence, or appear to influence, the exercise of your judgment against the interests of the Company is prohibited.
    3. Employees are prohibited from releasing any confidential Company information to an unauthorized fellow employee or to anyone outside the Company, unless authorized by an officer of the Company

Given that Pan African Airlines (Nigeria) Limited is a Nigerian company – and proud of it – we want to ensure that all employees and representatives of PAAN are clear about what is expected and required from a Nigerian context but Section c above regarding compliance with laws, rules and regulations. As a result, we can confirm that, within Nigeria, Pan African Airlines (Nigeria) Limited therefore specifically expects and requires all employees and representatives of PAAN to comply with all applicable Nigerian laws, rules & regulations at all times, including without limitation the following fundamental Nigerian laws, rules & regulations relating to Fraud, Theft and Business Malpractice:

  • Economic and Financial Crimes Commission Act 2004
  • Corrupt Practices and other Related Offences Act 2004
  • Advance Fee Fraud Act 2006
  • Money Laundering (Prohibition) Act 2004
  • Criminal Code Act 2004
  • Criminal Procedure Act 2004
  • Code of Conduct Bureau and Tribunal Act 2004
  • Companies and Allied Matters Act 2004
  • Miscellaneous Offences Act 2004

Failure to comply with any applicable law, rule or regulation will be considered a serious disciplinary offence, which will be immediately dealt with in accordance with the Company’s HR policies and procedures and could lead both to termination of employment and to matters being referred to the appropriate authorities.

These policies apply to the Company, its affiliated companies, and controlled joint ventures and to all employees, officers, and directors of the Company. Each employee must exercise good judgment and avoid any circumstance that would violate the letter or spirit of these policies. There are no exceptions to these policies, and violations will be subject to disciplinary action, up to and including dismissal from the Company.

HRH The Otunba Adekunle Ojora
Chairman

Alan Grant
Managing Director