IN THE FEDERAL
HIGH COURT OF NIGERIA
IN THE
OWERRI JUDICIAL DIVISION
HOLDEN AT
OWERRI
AFFIDAVIT OF FACTS
I, CHIMA
OKOYO, male, adult, Christian, and a Nigerian citizen of No. 24 Chikwere
Street, Douglas, Owerri, Imo State, do hereby make this oath and state as
follows;
1. 1. That I am the Deponent
herein.
2. 2. That I was the Customers Service Manager of
Ecobank Plc between October, 2006-
December, 2010 at Ngwa Road Branch, Aba Abia State.
3. 3. That subsequent to that, I also became the
Customers Service Manager between January, 2011- January, 2013 in Okigwe Brach,
Owerri
4.
That between Feb 2013-April, 2013, I became
the Customer Service Manager of Assupmta Road, Owerri, Imo State branch of
Ecobank.
5.
That more so, I became the Ecobank Zonal
Cordinator of Abia/Imo Zone from May, 2013 - August, 2013.
6.
That for my diligent and dedication to
work, I was given the best customer service manager in South East and South
South Region.
7.
That I have gone through the letter dated
the 10th day of April, 2015 which was directed to me by the ICAN
Investigation Panel, especially the deposed complaint against me, which was
conveyed by the said letter by Ecobank Bank Plc and in reaction to same, I
state as follows:
a. That paragraph 4 of the said affidavit
conveyed is false, baseless, malicious, defamatory of my noble character and is
bereft of authenticity. In response to same, I state correctly that I never,
either personally or in collaboration with anybody, either sometimes in 2012,
2013 or any other year committed any fraud in ECOBANK or any other bank to the
tune of N116.91 million or of any other figure.
b. That
paragraph 5 of the Affidavit is false and I also deny same. To the best of my
knowledge, the verification of Imo State branch account with Hallmark Bank of
which I was alleged to have done by the deponent therein never had anything to
do with me.
c.
That from my private investigations which I
carried out to exonerate myself, the alleged verification took place in the
year 2008 and as at that year, I was still working at Aba and not yet in Imo
State. I merely commenced work in Imo State in the January 2011 and prior to
then, the said account have been verified contrary to the allegation levelled
against me.
d. That I
know as a matter of fact and by bank practice that such verification exercise can
only be carried out by a relationship manager/officer of a bank of which I was
never, contrary to an operation staff where I belong.
e. That
after I was wrongfully accused by Ecobank to the effect that I did the
verification excercise, in a bid to
clear myself of the false accusation, I personally conducted a private
investigation to ascertain who did the verification.
f.
That the outcome of my investigation
reveals to me that it was one Uche Okpara, who was then a relationship officer
at the Okigwe Road Branch of Ecobank Owerri that did the verification.
g. That as
a matter of fact, I brought this outcome of my investigation to Ecobank Plc for
it to take necessary action and consequentially absolve me of their wrong
accusation but they never took my concern serious.
h. That I
know as a matter of fact that while Ecobank kept on delaying over taking up
action as I hinted them, the said Uche Okpara got clue of the situation and
absconded till date.
i.
That paragraph 6 of the affidavit is also
consequentially false. I never at any time verified nor accessed any money in
relation to those said bank accounts.
j.
That paragraph 7 of the affidavit is false
and is hereby denied. I never authorised nor saw to the transfer of any of the
cash stated therein. My private investigation did reveal to me that the N82, 400,000 was allegedly authorised
during the period the bank was doing system integration of its software with
legacy Oceanic Bank which the outcome was disaster and many authorisers lost
their profile to fraudsters. As for N12,230,000
I was no longer the staff of Okigwe Road branch as at the time the alleged
fraud took place there.
k. That I
have made my presentation to ECOBANK Plc over my innocence relating to the
allegations but they paid deaf ear to all my explanations as revealed from my
private investigation.
l.
That it is on record that in 2014, system
credited various customers account and it was too late before the bank
discovered and lost billions of naira. And specifically 13th
February 2015 another CSM in Aba profile was stolen which prompted the bank to introduced
Token (random password). If proper investigations have been done in my case, these
subsequent system frauds would have been prevented.
m.
That even when Ecobank took me to EFCC
Portharcourt with their alleged proof of crime against me, the EFCC Harcourt
did their investigation and found out that none of the document presented by
the bank bear my signature.
n. That more
so, the customer whose account contained all the alleged money was arrested by
EFCC through personal risk I took and I was cleared of any wrong doing when
customer admitted that I was not involved in their fraudulent transactions.
o. That is
of the fact that Ecobank investigated all my account in all banks without any
of such funds traced to me.
p. That
while indeed I did appeared before the ECOBANK disciplinary committee over
unfounded allegation of fraud, every other material deposition in paragraph 8
therein is false and hereby denied.
q. That
further to the above paragraph, when I appeared before the Ecobank Disciplinary
committee, the Committee members never gave me the opportunity to defend myself
over the allegations. They took to the side of the Bank that employed them and
denied me justice or hearing.
r.
That I admit paragraph 9 of the said
affidavit as true, save to say to state that the Bank’s none justifiable reason,
upon which I was wrongfully dismissed from work was solely upon their
allegation that I authorised fraudulent transaction, without more.
s.
That Ecobank did not only unlawfully
dismiss me from its services, it equally obtained power of prosecution over
which it is prosecuting me in CHARGE NO: OW/380C/2013 which
said charge still pends in the Owerri magistrate Court; its next hearing date being
24th April, 2015.
t.
That till date, no court of law has found
me to have committed any crime as alleged, even as EFCC from their
investigation aforesaid saw no basis for my prosecution.
u. That I
am innocent of all the allegations levelled against me by Ecobank.
8. That I
make this oath in good faith for record purposes, conscientiously believing same to be
true and correct to the best of my knowledge and in accordance with the Oaths
Act 2004.
………………
DEPONENT
SWORN TO AT THE FEDERAL HIGH COURT
REGISTRY, OWERRI
THIS………. DAY OF ……………………..2015
BEFORE ME
…………………………………………..
COMMISSIONER
FOR OATHS
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