NSE WHISTLEBLOWING POLICY
Nairobi Securities Exchange PLC (NSE or the Exchange) is committed to integrity, transparency, accountability, ethical conduct and good governance across its operations and stakeholder interactions.
Through the NSE Whistleblowing Programme, employees, directors, contractors, service providers, trading participants, listed companies, investors, customers, suppliers, regulators and members of the public may confidentially report suspected wrongdoing affecting NSE, its stakeholders or the integrity of Kenya’s capital markets.
What Can Be Reported?
Reports may relate to enterprise misconduct or market-related misconduct, including:
- Breaches of laws, regulations, NSE Rules, internal policies, codes of conduct or delegated authority requirements;
- Fraud, bribery, corruption, extortion, embezzlement, money laundering, procurement irregularities, misuse of NSE funds, information, systems or assets, and conflicts of interest;
- Market abuse, market manipulation, insider trading, misuse of confidential information or conduct that may compromise investor protection, market fairness or public confidence;
- Retaliation against whistleblowers, concealment of misconduct, interference with investigations, destruction of evidence or conduct that threatens NSE operations, personnel, systems, stakeholders or reputation.
Confidentiality and Protection
NSE will handle reports confidentially and restrict case information to authorised persons on a need-to-know basis. Reports may be submitted anonymously, pseudonymously or on an identified basis. Any person who makes a good-faith disclosure, or participates honestly in a review or investigation, will be protected from retaliation, victimisation, harassment, discrimination or other detrimental treatment. Malicious, knowingly false or bad-faith allegations may be addressed through appropriate disciplinary or legal processes.
Data Privacy and Data Handling
Information submitted through the portal will be used only for whistleblowing intake, assessment, investigation, reporting and related governance purposes, and will be safeguarded in accordance with applicable data protection requirements and NSE policies.
Reporting Channels
Whistleblower reports may be submitted through approved NSE channel:
Online: NSE Whistleblowing Portal
Review and Investigation
All reports will be logged, screened and assessed promptly to determine credibility, urgency, scope, potential impact, available evidence and the appropriate response. Matters may be handled through preliminary assessment, management action, internal investigation, independent review, referral to the Capital Markets Authority, law enforcement, anti-corruption authorities or other relevant agencies, or closure where the matter is outside scope or unsupported. Intake and case tracking will be coordinated independently, with oversight through NSE’s governance structures to support accountability, independence, impartiality and effectiveness.
Speak Up. Protect Integrity.
Every good-faith report helps strengthen NSE, protect stakeholders and safeguard Kenya’s capital markets. NSE encourages all employees and stakeholders to speak up responsibly and in good faith.