REVIEWED FORCE ORDER 235 -

COMPLAINTS AGAINST POLICE OFFICERS

Table of Contents
Foreword .........................................................................................................................................................3

REVIEWED FORCE ORDER 235 - COMPLAINTS AGAINST POLICE OFFICERS ..................................................... 4

1. Purpose........................................................................................................................................................4

2. Standards of Conduct of Police Officers .......................................................................................................5

3. The Attributes of a Police Officer .................................................................................................................5

4. Police Regulations ........................................................................................................................................5

5. Handling Public Complaints .........................................................................................................................6

6. Establishment the Public Complaints Bureau (PCB)......................................................................................6

6.4. Functions of the Public Complaints Bureau: ..............................................................................................6

6.5. Role of PCB Investigator: ...........................................................................................................................7

6.6. PCB Training and Skillset ...........................................................................................................................7

7. Complaints against the Police ......................................................................................................................8

8. General Complaints .....................................................................................................................................8

8.3. Complaints against Police Officers while On Duty .....................................................................................8

8.4. Complaints against Police Officers while Off Duty .....................................................................................9

9. Procedure for Handling Complaints .............................................................................................................9

9.1 Notification of Complaints .........................................................................................................................9

9.2 Recording and Initial Assessment ......................................................................................................... 10

9.2.3. Determining Trivial, Frivolous, Vexatious, Bad faith Complaints/Issues ............................................. 11

9.2.4. Process ................................................................................................................................................. 11

9.3 Complaint against Senior officers ......................................................................................................... 11

Complaints against the PCB Officers .............................................................................................................. 13

9.5 Complaint against Junior Officers ......................................................................................................... 13

9.6 Complaint by Person(s) in Police Custody ............................................................................................. 14

9.7. Complaint against Police Formation ........................................................................................................ 14

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9.8. Complaint against Quality of Service .......................................................................................................14

10. Investigation ............................................................................................................................................15

10.7. Determination of Outcome of Investigation ..........................................................................................16

10.8. Report Writing ......................................................................................................................................16

10.9. When a Complaint is Withdrawn ..........................................................................................................16

10.10. Handling Difficult Complainants ..........................................................................................................17

11. Notification to Complainant .....................................................................................................................17

11.8.1. Recognition: .......................................................................................................................................18

11.8.2. Responsibility: ....................................................................................................................................18

11.8.3. Reasons: .............................................................................................................................................18

11.8.4. Regret: ...............................................................................................................................................19

11.8.5 Redress ...............................................................................................................................................19

11.8. 6. Release ..............................................................................................................................................19

11.9 Promoting Learning and Accountability .................................................................................................19

12.1. Organisational Learning: .......................................................................................................................19

12.2. Accountability and Transparency: .........................................................................................................19

APPENDIX A: Handling Unreasonable Conduct ..............................................................................................20

APPENDIX B ...................................................................................................................................................25

Chart ..............................................................................................................................................................31

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Foreword
Public complaints about how police services are delivered are not new. The way the Nigeria Police
responds to criticisms of the conduct of its personnel, police units or the Force itself has a major impact
on our operational effectiveness, legitimacy and our image in the public eye. It is our intention to
support the development of a system that promotes the right of members of the public to complain
and enables the Police to receive and respond to complaints promptly. In this regard we are committed
to promoting and implementing an accessible complaints system as a means to address problems with
service delivery and to enhance the performance of the Force and its officers. We are aware that as a
community-oriented police force, promoting and encouraging complaints and responding to them fairly
and promptly will strengthen community policing relationships, identify problems, improve our service
delivery systems and improve police-public relationships.

This revised Force Order 235 is meant to streamline and standardise the process of handling complaints
in the police. The steps in the successful management of complaints against the police are clearly
explained to ensure all relevant information is captured. Personnel of the Public Complaints Bureau
(PCB) who are to handle this process must take this responsibility with all the professional seriousness
it deserves. Members of the public making complaints should not be victimised but should be treated
with the utmost respect and dignity they deserve. PCB personnel should take all reasonable steps to
ensure that people making complaints are not adversely affected because a complaint is made by them
or on their behalf. They should address each complaint with integrity and in an objective and impartial
manner.

The commitment of all police officers is critical to the management of complaints system effectively. A
commitment to good complaint handling is needed at all levels within the Force. When complaints are
handled fairly, transparently and in a timely manner, staff morale improves and public confidence in
our services is secured. Police officers should note that the focus of complaint handling is on fixing
issues and improving systems, not apportioning blame.

One of the advantages of having a reviewed process is that it affords us the opportunity to implement
changes to services, systems, practices, procedures where weaknesses are identified through the
management and analysis of complaints, and communicate to staff and the public changes made.

By approving this reviewed Force Order, we want to send a clear message to all police officers that
complaints can be a valuable source of feedback on the quality of service we provide to the Nigerian
public. This new Force order will be made publicly available on how complaints can be made to the
Police and how they will be managed.

IGP Mohammed Adamu Abubakar NPM, mni

Inspector General of Police,

Federal Republic of Nigeria

2019

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REVIEWED FORCE ORDER 235 - COMPLAINTS AGAINST
POLICE OFFICERS
1. Purpose
1.1. The Nigeria Police Force has a constitutional mandate to protect lives and properties, prevent and
detect crime, preserve law and order amongst others. To achieve its mandate of delivering high quality
services, the Police has put in place systems and processes to ensure effective and efficient service
delivery. ln furtherance of the good name of the Force, (see section 338 of Police Regulations) “Police
Officers are expected to perform such duties as may be assigned by the Inspector-General of Police,
or by an officer authorised by the Inspector General of Police.” However, by acts of commission or
omission things may go wrong and mistakes may be made.

1.2. This Force Order 235 (FO 235) is issued to provide avenues for members of the public to present
their grievances or complaints about either the quality of the policing services provided and/ or the
actions of an individual Police Officer. Members of the public need to have confidence that when they
raise a concern about police services or their treatment, they will receive adequate attention with their
complaints investigated and appropriate actions taken. Any member of the public making any complaint
shall be treated with proper courtesy and the final disposal of the complaint shall be made known to the
complainant as expeditiously as possible. In addition, this FO 235 is designed to provide valuable
information about how services are provided and to identify weaknesses in the policing system that
consistently fail to meet public needs and expectations and need revision.

1.3. The reviewed FO 235 is approved and issued by the Inspector-General of Police (IGP) to improve
police complaint handling system in order to help strengthen accountability, integrity and transparency
in checkmating the excesses of police personnel. Through a system of promoting and encouraging
complaints and responding to them fairly and promptly, the IGP hopes to strengthen relationships,
identify problems, improve quality of policing and improve services rendered to members of the public.
It should also be recognised that the complaints process provides the opportunity to explain actions or
omissions that were lawful and appropriate.

1.4. This Force Order is also designed to promote a culture of learning both for the individual Police
Officer and the Force. Through a comprehensive and effective complaint handling system, the Force
will have the opportunity to measure current performance, assess public expectation, improve service
delivery and prevent repetition of complaints. Learning can include changes to current practices and
policies or can involve development training programmes for Police Officers. It is equally important that
good practice is identified in order that all parts of the organisation may benefit from lessons learned.

1.5. To prevent any reoccurrence, significant issues identified during the investigation of a complaint
should be addressed without waiting on the conclusion of the complaints.

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2. Standards of Conduct of Police Officers
2.1. In accordance with Regulation 339, in the discharge of his or her responsibilities, the standards of
conduct required of a Police Officer are that he/she shall:

a) offer prompt obedience to lawful orders;

b) be determined and incorruptible in the exercise of his/her police duties;
c) have a strict regard to the correctness of his/her general behaviour;
d) take a proper pride in his/her appearance both in uniform and out of uniform.

3. The Attributes of a Police Officer

3.1. Section 340 of Police Regulation articulates the attributes of a Police Officer thus: In the discharge
of his or her responsibilities a Police officer is expected to exhibit certain attributes. The Officer is
required to have a thorough understanding and knowledge of the laws, and of police orders and
instructions, and to develop the attributes of:

a) efficiency and thoroughness through meticulous attention to details in the performance of

his/her duties;
b) courtesy, forbearance and helpfulness in his dealings with members of the public;
c) tact, patience and tolerance, and the control of his/her temper in trying situations;
d) integrity, in refusing to allow religious, racial, political, or personal feelings, or other
considerations, to influence him/her in the execution of his/her duties;
e) impartiality, in the avoidance of feelings of vindictiveness, or the showing of vindictiveness
towards offenders;
f) strict truthfulness in his/her handling of investigations, and in the giving of evidence.

4. Police Regulations
4.1. Complaints may or may not include allegations of misconduct against Police Officers. The Police
Act, First Schedule (Regulation 370), prescribes offences against discipline. Generally, complaints
against a Police Officer alleging an act or omission, either criminal or non-criminal falls under the
following headings and may be subject of investigation by the Police Complaints Bureau (PCB) where
complaints are lodged:

a) Assault and police brutality

b) Excessive use of Force
c) Insubordination or Incivility to members of the public
d) Unauthorised/illegal duty
e) Abuse of power
f) Breach of confidence
g) Disorderly conduct
h) Extortion and official corruption
i) Neglect of Duty
j) Police involvement in criminal activities
k) Suppression of complaints
l) Unlawful and Unnecessary exercise of authority
m) Without a good and justifiable cause makes an unlawful or unnecessary arrest
n) Uses unnecessary violence to any prisoner or other person with whom he/she may be
brought into contact in the execution of his/ her duty.

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5. Handling Public Complaints
5.1. In handling public complaints against the Police, the Nigeria Police Force intends to achieve the
following:

a) to boost public confidence in the Police;

b) to ensure complaints are dealt with in a fair, consistent, objective and professional manner;

c) to try and resolve public concerns and where necessary take actions to put things right;

d) to offer apologies and explanations where mistakes are made;

e) to ensure that complaints that are criminal in nature are thoroughly investigated;

f) in cases where misconduct is established, ensure the appropriate disciplinary proceedings

are instituted;

g) where complaints cannot be resolved by explanation or apology, such complaints to be

subjected to thorough investigation and the complainant kept abreast of outcome;

h) where appropriate, review and change policies, procedures or practices;

6. Establishment the Public Complaints Bureau (PCB)

6.1. There shall be PCB offices at the Force Headquarters, every Police State Command and Zonal
Command and this office should be under the supervision of the Public Relations Office.

6.2. This FO 235 has been developed to help the PCB conduct investigations that cover complaints
against police misconduct or disciplinary issues. It must be read in conjunction with any statutory
provisions and guidelines applicable to the investigation being undertaken.

6.3. The investigation of complaints involving allegations of criminal conduct must be referred to the
appropriate criminal investigation unit.

6.4. Functions of the Public Complaints Bureau:

The PCB shall be saddled with the following responsibilities:

a) Conduct objective and painstaking investigations of all complaints against the Police;
b) Take a citizen-focused approach to handling complaints;
c) Ensure that information about how and where to complain is kept up-to-date and available at
all PCB offices;
d) Ensure that the process of making complaints is easy to access and understand, particularly for
members of the public that may require additional assistance or different approaches such as
people with disabilities, people living in remote communities, children and young persons, and
people who do not understand the English language;
e) Acknowledge complaints in a timely manner, address complaints promptly and according to
the order or urgency and keep the complainant informed throughout the process;
f) Deal with complaints in an equitable, objective and fair manner; clarify key issues of the
complaint to the complainant; act with courtesy, showing empathy and understanding and
remain impartial;

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 g) Annexing case files, parties, exhibits in all cases which are subject of petitions and complaints
and adherence to best practices in subsequent investigations;
h) Conclusive investigations into conducts of errant police officers in accordance with the law,
professional ethics, official guidelines and set procedures;
i) Maintain a continuous inspection of Police detention facilities, and interview inmates to
determine their state of detention.

6.5. Role of PCB Investigator:

The PCB Officer handling any investigation should:
a) Ascertain all relevant facts pertaining to the complaint;
b) Have the skills to be able to act with sensitivity as well as be objective and impartial;
c) Have knowledge of, and be able to advise on, all aspects of the PCB procedures and be
trained to receive, investigate and deal with complaints;
d) Ensure that complainant’s confidentiality is maintained, and their rights respected;
e) Ensure that they are not directly involved in the subject matter of the complaint, and inform
the Head of PCB should such an issue arise;
f) Act without bias, reach conclusions and form views on the facts of the case, whilst
considering matters that are relevant and not those that are irrelevant;
g) Keep personal information relating to the complaints confidential;
h) Be able to assist in the formulation of a written complaint for complainants who require
additional assistance;
i) Have access to Police Officers at all levels so that complaints can be resolved quickly;
j) Have clearly defined power to act and provide redress to complainants or to refer the matter
to someone who has this power; and

k) At the conclusion of investigation, report findings; give reasons for the findings, referring to
the material on which they are based, and, if appropriate, make relevant recommendations.

6.6. PCB Training and Skillset:

PCB Officers who are responsible for responding to and/or resolving complaints against Police Officers
should possess or be given guidance or training in customer contact and communication skills.
Guidance and training of PCB Officers should cover:

a) Complaint handling procedures and legal framework for complaint handling in the Police;

b) Declaration of and managing conflict of interests;

c) Evidence based investigation skills;

d) Skills in alternative dispute resolution such as mediation and conciliation;

e) Interpersonal skills, such as listening, interview skills and conflict management;

f) Communication skills for dealing with unreasonable complainant conduct or the unreasonable
conduct of a Police Officer who is the subject of the complaint; and

g) Record keeping procedures.

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7. Complaints against the Police
7.1. A complaint about the police can be made by any of the following:

a) a member of the public who claims to be the person in relation to whom the act or commission
took place;

b) a member of the public who claims to have been adversely affected by the act or omission even
though it did not take place in relation to him or her;

c) a member of the public who claims to have witnessed the act or commission;

d) An authorized or recognized external organization such as an oversight body or any other

group, or an individual acting on behalf of a person in the three categories above (if he or she
has and can produce consent from the other person).

8. General Complaints
8.1. Complaints against the police can come in different categories. They could be criminal or non-
criminal when they are ‘on-duty’ or ‘off-duty’. Complaints could also be made against the quality of
service rendered by a police department or police station.

8.2. A Police Officer is said to be ‘on-duty’ while operating within officially assigned hours. A Police
Officer could also be regarded to be on duty when, while off duty, identifies himself or herself as police
personnel verbally or by the production of his or her warrant card and attempts to use police powers to
respond to a situation that if not responded to, will be considered as neglect of duty. By this action, he
or she is regarded to have returned to on-duty capacity.

8.3. Complaints against Police Officers while On Duty

8.3.1. Where the PCB receives a complaint against a Police Officer in the performance of his or her
duty, and there are reasonable grounds that a crime may have been committed, the matter shall
immediately be referred to the State CID for investigation. The State CID shall immediately take
appropriate reasonable steps to obtain the statements of the complainant within 24 hours from which
the report was referred to it.

8.3.2. Where the offence complained against the officer on duty is not of a criminal nature, the officer-
in-charge of PCB shall assess the complaint within 3 to 5 days of the receipt of the complaint to
determine whether or not mediation is necessary. Where the officer finds the complaint to be minor or
trivial, he or she shall immediately invite the complainant to explore the possibility of mediation. The
Officer shall take all reasonable steps to ensure that the complainant is pacified and the Officer
complaint against made to apologise and/ make restitution if necessary. Where mediation cannot be
achieved or the complainant is not willing to accept apology and/or remedy, the complaint shall be
assigned to the PCB investigation Officer.

8.3.3. Where the non-criminal offence complained against a Police Officer is serious or complex in
nature, the PCB shall begin the immediate and unbiased investigation of the alleged offence.

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8.4. Complaints against Police Officers while Off Duty
8.4.1. There are situations where complaints are made against Police Officers who commit acts of
misconduct or offences against discipline while off duty. However, for the matter to be considered as a
complaint about the Police, it must directly relate to the individual’s role as a Police Officer. Every
complaint must be assessed objectively, and consideration shall be given to whether a link exists
between the situation complained about and the role of the Police Officer. The complaint should be
treated as a complaint about the Police only if the conduct (if it was to be established) relates to, or
would have a bearing upon, the person's role as a police officer or the image of the police organisation
as an institution. Where no such link can reasonably be established the matter should not be recorded
as a complaint about the police and the complainant should be politely advised of this. It must be
remembered that Police Officers have a right to privacy away from work. If the police officer commits
an offence in his or her private capacity, it must be treated as such.

8.4.2. If on the other hand, a criminal complaint is made about a Police Officer while off duty, it shall be
recorded and referred to the State Criminal Investigation Department for investigation in accordance
with the nature of the criminality involved. The Police Officer shall then be treated as any other member
of the public.

8.4.3. Where, during an investigation, there is a likelihood of an officer undergoing interview under
caution being detained or arrested, the Commissioner of Police or head of the Police Unit where he or
she is presently serving shall be notified within 48 hours or as soon as practicably possible.

9. Procedure for Handling Complaints

9.1 Notification of Complaints
9.1.1. The PCB shall receive or be notified of complaints by various means including, verbal complaints
in person, by telephone; written form via petition, email, police website, or by a third party acting on
behalf of a complainant or social media e.g. Whatsapp, Facebook, Instagram, etc.

9.1.2. Verbal complaints shall be recorded in writing by the PCB officer and filed in the Incident Register
for accurate record and case management (see appendix B).

9.1.3. All complaints shall be taken on face value and, in the absence of strong and clear evidence to
the contrary, must be assumed to have been made in good faith. Complaints must be considered on
their own merit.

9.1.4. All complaints shall be assessed within three to five working days of receipt, except where the
issues complained about are complex or are criminal in nature. Receipt of such complaint shall be
acknowledged within working three to ten days, and the complainant informed of the progress of their
complaint within six weeks.

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9.1.5. All complaints cases shall be logged and allocated a unique PCB reference number which should
be visible on all documentation relating to that case.

9.1.6. Where the complaint does not fall within the responsibility of the PCB, such complaint shall also
be accepted and acknowledged within three to five working days, and the complaint shall be forwarded
to the appropriate office to handle. The complainant shall be advised and redirected to the office
handling his or her complaint.

9.1.7. It is important that in the process of handling a complaint, the expectations of the complainant
are identified and managed properly. The success of the investigation of a complaint shall depend on
the willingness and co-operation of the complainant.

9.1.8 In cases where the complainant shows acute signs of anxiety assistance of a psychologist should
be sought.

9.1.9 Children and under aged complainants will require to be accompanied by an adult and referred to
a centre appropriate for minors

9.2 Recording and Initial Assessment

9.2.1. All complaints received shall be properly filed for effective handling of the complaint. The PCB
officer receiving and filing the complaint shall consider whether it is relevant under the Police Act and
Regulation. Any complaint made against a senior officer shall be investigated by an officer senior in
rank to the officer complained against.

9.2.2. Once a complaint has been received by the PCB, an assessment of the complaint shall be
conducted to ascertain the nature of the complaint and the seriousness of the allegation. The Initial
assessment will include an evaluation of: -

a) Whether the complaint raises potential issues of Offences Against Discipline that could be
subject of investigation by the Public Complaint Bureau (PCB);
b) Whether the complaint raises potential issues of crime that should be investigated by the State
CID;
c) Whether the issue raised is, in the opinion of the PCB Officer trivial, frivolous or vexatious or
made in bad faith;
d) Whether all information required to address the complaint is included and, if not, how this
information can be obtained; and
e) Whether in the case of a complaint, having regard to all the circumstances of the case, an
investigation of the complaint is unnecessary or unjustified;
f) Whether the complaint indicates or exposes the existence of a systemic problem within the
Police;
g) Whether the conduct that is subject of complaint has been previously investigated and disposed
of; or whether it is one of a series of complaints, indicating a pattern of conduct or a widespread
problem within the Police;
h) Whether the nature of the complaint is gender related and should involve the appropriate
gender approach

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9.2.3. Determining Trivial, Frivolous, Vexatious, Bad faith
Complaints/Issues
The PCB investigator will consider the following in determining whether an issue is trivial, frivolous,
vexatious or bad faith:
a) For trivial or frivolous: a trivial or frivolous complaint is one which raises issues that are
unimportant, petty, or insignificant. Is the complaint or issue supported by facts or is it purely
speculative or hypothetical in nature? Is it a situation where there is no justifiable reason to
investigate?
b) For vexatious or bad faith: A vexatious or bad faith complaint is one commenced for an
improper purpose, such as to harass, embarrass or annoy. A complaint will also be vexatious
if it is duplicative of a pending complaint, or if it seeks to re-raise an issue that has already been
determined; Is the complaint/ issue pursued for an improper purpose? Is the complaint
/issue intended to annoy or embarrass?

9.2.4. Process:
a) Where a complaint made in writing or verbally has been assessed and considered to be trivial,
frivolous, vexatious or made in bad faith, and there is no evidence that may support any
investigation, the complaint shall be dismissed by the Officer-in-charge PCB;
b) Where a complaint made in writing or verbally has been dismissed as trivial, frivolous, vexatious
or made in bad faith, the complainant and the Police Officer complaint against shall be notified
of the dismissal. However, the Officer-in-charge PCB shall notify the complainant of his or her
right to appeal to the Commissioner of Police for a reconsideration of the complaint within
twenty working days;
c) In reviewing the decision of the Officer-in-charge PCB, the CP shall consider whether the
decision was reasonable in the light of the information in the possession of the Officer-in- charge
PCB at the time of the decision. Where the CP concludes that the Officer-in-charge PCB
reached a reasonable decision, the CP will stick with the decision of the officer-in-charge PCB.
However, the CP may overturn the decision of the officer-in-charge where he/she identifies a
clear error on the part of the officer-in-charge PCB. The CP will ensure decisions are
communicated to the complainant and the officer complaint against within five to ten working
days.

9.2.5 The primary task of assessment of the complaint and determination of the nature of the
investigation is to consider the content of the complaint ensuring that it is dealt with in the most
appropriate manner and in line with the relevant legislation or regulation.

9.3 Complaint against Senior officers

9.3.1. For the purpose of maintaining discipline, members of the Force shall not accept as forwarding
agents or take any action on complaints made to them either verbally or in writing against an officer
senior in rank.

9.3.2. Where such complaint is received verbally, the PCB officer who listened to the complainant shall
enter in his or her notebook or official diary the name and address of the complainant, and particulars
of the complaint given to him or her.

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9.3.3. Where a written complaint is received, the PCB officer shall, as soon as is reasonably
practicable (at least within two to five working days) after receiving the complaint cause the written
complaint to be forwarded without comment to the Commissioner of Police of the State Command or
other Police Commands.

9.3.4. Where the complainant in question is illiterate, the PCB officer receiving such complaint shall
advise the complainant to produce an interpreter. Where the complainant cannot produce an interpreter,
the PCB officer or any officer receiving the complaint shall provide an interpreter that is acceptable to
the complainant.

9.3.5. Where the person making the complaint is of a foreign nationality, and does not speak English,
the PCB officer shall cause a letter to be written or make a phone call to the Embassy of the country of
origin of the complainant, to provide an interpreter for the complainant.

9.3.6. However, where the complaint being received is to the fact that the Senior Officer has committed
a criminal offence, the receiving officer shall take immediate action and proceed with preliminary
investigation as he or she would normally handle if the offender were not a member of the Force, until
the casefile is transferred to the State CID.

9.3.7. In all circumstances, the following procedure shall be observed:

a) The PCB shall forward the written complaint to the Commissioner of Police (CP), Assistant
Inspector-General of Police (AIG) in-charge Zone or Commandant of the Police Training
institution for necessary action;
b) Upon receipt of such complaint, the CP, AIG or Commandant shall immediately instruct the
Officer complained against to submit written comment to the complaint if the complaint is non-
criminal. Where the complaint is criminal in nature the State CID or Zonal CID shall be directed
to investigate. The result of such investigation shall be forwarded to the IGP for necessary
action.
c) In the event of any disciplinary offence being disclosed, the IGP shall forward the complaint
together with the report of the officer who conducted the investigation or the written comment
to the complaint to the Police Service Commission for further action.

9.3.8. Where the complaint is recorded through the media, the Police Public Relations Officer (PPRO)
of the Command, Zonal Command, or Training Institution shall call the attention of the CP, AIG, or
Commandant concerned who will instruct the Officer-in-Charge PCB to commence investigation. Where
the offence is criminal in nature, the CP, AIG, or Commandant shall direct the State CID or Zonal CID
to investigate.

9.3.9. Where the complainant is a physically challenged person, the PCB officer shall ensure the
complainant is given the necessary facilities or disability aid required to document his or her complaint
in writing.

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Complaints against the PCB Officers
9.4.1. Where the complaint is against a staff of the PCB such complaint shall be forwarded to the
Commissioner of Police;

9.4.2. Where it is established that the PCB Officer has a case to answer, the CP shall assign an officer
senior in rank, but not a member of the PCB to investigate the complaint.

9.4.3. Where after initial assessment of the complaint against the PCB Officer, the complaint is viewed
as trivial, frivolous, vexatious or in bad faith, the CP shall dismiss the complaint and inform the
complainant and the PCB Officer complaint against accordingly.

9.5 Complaint against Junior Officers

9.5.1. Any complaint against a Non-Commissioned Officer (NCO) or an Inspector shall be investigated
by an officer senior in rank to the officer complained against.

9.5.2. The procedures enumerated above shall be followed.

9.5.3. The complainant shall be invited to attend to the enquiry with his or her witness(es), if any, and
the Police officer or Officers complained against shall also be present and may produce witness(es) on
their behalf if they so desire. Before inviting the Police Officer complaint against, the PCB Officer shall
ensure that the allegations have assessed and have some substance. Where there is a case to answer,
the Police Officer should be treated with procedural fairness.

9.5.4. The PCB officer investigating the complaint shall conduct initial assessment of the complaint and
if he or she is satisfied that no disciplinary or other offence has been committed shall;

a) Prepare a short summary of the evidence of his or her findings, and

b) inform the complainant in writing that no further action is contemplated by the Police against
the Police Officer(s) complained against;

9.5.5. Where the investigation discloses criminal offence against the Police officer(s), complained
against, the PCB Officer conducting the investigation shall close and summarize the proceedings,
record his or her findings and forward the casefile to the State CID.

9.5.6. Where after investigation, the PCB officer has established on the balance of probabilities, that a
disciplinary offence has been committed, he or she shall adjourn and formally charge the Police
Officer(s) with the disciplinary offence or offences alleged to have been committed.

9.5.7. The PCB officer conducting the investigation shall re-open the investigation and refer same to
the Provost Marshall who will conduct the proceedings as an Orderly Room in accordance with the
procedure laid down in Police Regulations.

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9.5.8. At the conclusion of the proceedings, the Officer shall inform the complainant in writing of the
disposal of the case.

9.6 Complaint by Person(s) in Police Custody

9.6.1. Where a person is detained in Police custody and wishes to make a complaint about the conduct
of a Police officer(s) performing duties in connection with the detention, such complaint shall be made
in writing or verbally;

9.6.2. Where the person elects to make the complaint in writing, the Charge Room Officer or Officer in-
charge the detention facility shall, at his or her request be provided with the writing materials necessary
to do so;

9.6.3. Where the person elects to make the complaint verbally, the officer to whom the complaint is
made shall, as soon as is practicable (at least within 48 hours) after the complaint is made, reduce the
complaint to writing.

9.6.4. Where such complaint cannot be mitigated by the Divisional Police Officer, it shall immediately
be forwarded to the PCB for investigation.

9.7. Complaint against Police Formation

9.7.1. Sometimes complaints could be made against a police formation regarding either quality of
service provided, or the police formation is accused of outright criminal activities.

9.7.2. Where a complaint is made against a Police Formation, the PCB will record the complaint and
conduct initial assessment.

9.7.2. Where the complaint is considered as non-criminal it shall be referred to the Police SERVICOM
for investigation. But where it is established that the police formation is engaging in criminal activities,
the CP shall immediately be informed, and the complaint referred to the CID for investigation.

9.7.3. Where the complaint reported to SERVICOM has been resolved or dismissed a report should be
sent to PCB office for appropriate recording.

9.8. Complaint against Quality of Service

9.8.1. Sometimes complaints could be made against to the Police organisation relating to either the
general direction and control of the Police, quality of service, policies of the Police, organisational
decisions, general policing standards in the country or operational management decisions.

14
9.8.2. Where complaints as enumerated above come to the notice of the PCB, it shall be immediately
forwarded to the Commissioner of Police who shall transmit it to the Inspector-General of Police for
his/her action. The person making such complaint shall be adequately informed of the procedure being
taken to handle the complaint including the outcome of the IGP’s intervention or actions.

10. Investigation
10.1. Every complaint shall be the subject of immediate, thorough, unbiased, impartial, confidential and
objective investigation. The task of investigation is to prove or disprove, if possible, any matter or
matters of fact raised by a complainant. No PCB Officer with actual or perceived conflict of interest shall
be appointed or remain the investigator. The more serious the complaint, the more important it is that
the investigator be an Officer as independent of the events being investigated as possible.

10.2 The PCB Officer in-charge any complaints under investigation shall ensure that he or she gathers
supporting evidence and information in respect of the facts upon which a decision will be based.
Evidence gathering relates to the identification, capture and recording of data relevant to the complaint
being investigated. The main sources of evidence are, oral evidence, documentary evidence, expert
evidence, and inspection of scene of incidence. Although only one witness may be required to prove
any fact or set of facts, additional evidence in the form of corroboration is desirable.

10.3. Where legal proceedings may arise at some future stage, such as Orderly Room Trial or court
trial, evidence shall be gathered in accordance with the rules of evidence. PCB Officers must have basic
knowledge of these rules to ensure that the evidence obtained is the best available and, where
applicable, will be admissible in any subsequent legal proceedings that may arise.

10.4. Complainant: The PCB Officer investigating shall manage the complainant’s expectations to
ensure they are based on a realistic understanding of what the investigation can achieve. Ensure their
confidentiality and explain the importance of confidentiality generally. Provide them with support,
information, and regular feedback, and inform them of the outcome of the complaint or other action, and
the reasons. The PCB officer shall note that the complainant has the right to see what has been
recorded if they request to do so.

10.5. Where the PCB officer considers that the complainant has not provided enough information or
supporting documents relating to the complaint under investigation, the complainant shall be contacted
either by letter, email, telephone or face to face meeting. All requests for further information or
documents shall be within five working days, however discretion may be applied to increase the number
of days allowed where considered appropriate. All evidence and information gathered should be clearly
documented within the case file.

10.5. Where the complainant fails to provide further evidence or information as requested by the
investigating PCB Officer, the officer shall consider a closure of the casefile based on evidence
available, or where no evidence has been provided, consider a closure of the casefile on the basis that
the case has been abandoned due to lack of co-operation from the complainant.

15
10.6. The complainant shall be notified advising them that their case file will be closed, and an
explanation given for this. The complainant shall be informed that should PCB receive, at a later date,
evidence in support of their complaint, the file shall be re-opened and the process shall be resumed. In
addition, the complainant shall be advised that closing the file on their complaint does not prevent them
from making a complaint in the future about an unrelated matter.

10.7. Determination of Outcome of Investigation

10.7.1. After a thorough and conclusive investigation, the PCB Officer shall carry out an objective
analysis of the evidence gathered. In determining his or her recommendation, the following points shall
be considered:

a) what prompted the complaint;

b) what facts have been established;
c) whether the action(s) of the Police Officer complained about was or were unsatisfactory and
should be avoided in the future;
d) what can be done to prevent a re-occurrence;
e) whether an apology is appropriate or a reimbursement in case of theft/loan /property loss;
f) what can be learned from the complaint?

10.8. Report Writing

10.8.1. At the conclusion of investigation, the PCB officer shall write a report to the Commissioner of
Police outlining the key points of the complaints and provide supporting information or evidence, for
consideration by the Commissioner of Police. The report should also contain the identified reason for
the discreditable conduct that has been established for the Commissioner of Police to take appropriate
action to correct. For example, the conduct may have been instigated by a lack of resources; training
issues; poor planning and supervision; a lack of coordination; lack of a conducive working environment,
a misunderstanding or a genuine mistake on the part of the officer(s).

10.9. When a Complaint is Withdrawn

10.9.1. Where a complainant informs that he or she wishes to withdraw a complaint in full, a signed
letter should be obtained from the complainant stating the reasons for the withdrawal.

10.9.2. Where a complaint is withdrawn in full, the investigation shall still be completed:

a) if the complainant expresses a lack of faith or confidence in the way his/her complaint was
handled;
b) if evidence exists that supports the complainant’s allegation(s);
c) if the complaint arose from a matter that is particularly sensitive or very serious in nature;
d) if the Police Officer complained against is part of multiple complaints.

10.9.3. Where a criminal complaint is such that cannot be compounded, it shall not be withdrawn, and
an explanation shall be offered to the complainant.

10.9.4. When an explanation has been offered to a complainant and is fully accepted, the allegation
should not be considered to have been withdrawn, nor should the complainant be prompted to withdraw
the allegation. The appropriate outcome is that the allegation is regarded as “concluded by explanation
to complainant”.

16
10.10. Handling Difficult Complainants
10.10.1. Where the complainant fails to co-operate with the PCB officers and the investigation
process, (e.g. failure to communicate with the investigators without good reason, persistent abusive
and offensive behaviour towards the PCB officer, or refusing to accept outcome of investigation) all
attempts to contact the complainant should be documented. Sometimes a complainant displays the
following conduct - unreasonable persistence, makes unreasonable demands, unreasonable lack of
cooperation, unreasonable arguments with PCB officers, or unreasonable conduct or behavior (See
Appendix A on Handling Unreasonable Conduct). The PCB should make all reasonable efforts to
secure the complainant’s co-operation.

10.10.2. PCB Officers should note that all complainants deserve to be treated with fairness and
respect. No complainant, regardless of how much time and effort is taken in responding to their
complaint, should be unconditionally deprived of having their complaint properly and appropriately
considered.

10.10.3. Where it is reasonably assessed that the complaint investigation process cannot proceed
without the complainant’s further co-operation, then consideration may be given to abandoning the
process. The decision to abandon a complaint should be communicated to the complainant in writing
or by the complainant’s preferred communication method. A complainant whose conduct is
unreasonable may have a legitimate complaint.

10.10.4. Where it is discovered at the end of investigation that the complaint against a police officer
is found to be frivolous, vexatious or malicious, the PCB shall proceed with criminal proceedings against
the complainant.

11. Notification to Complainant

11.1. Communication is a key element of any action taken in the handling of complaints right from the
start of investigation. PCB officers must be in constant communication with the complainants, providing
updates and progress of the investigation of their complaints. Also, there must be clear channels of
communication between the PCB officers and supervising senior officers.

11.2. There are situations where both criminal and non-criminal complaints will be made against officers
arising out of an incident. While accepting that there may be delays in handling the criminal complaint,
it is important that the non-criminal complaint be addressed as early as possible, and Orderly Room
proceedings concluded as soon as practicable. In all situations, the complainant must be informed about
the progress of his or her complaint.

11.3. Where a complaint has been resolved amicably between the complainant and the officer
complained against, the PCB Officer handling the resolution must document the proceedings and a
written letter be provided to the complainant. Where a complainant accepts a verbal explanation, a
written letter must always be provided.

17
11.4. If a complaint has been dealt with and a decision is taken to either proceed or not with misconduct
proceedings, the complainant should be notified of the outcome and of the reasons for the outcome
being reached. Any decision or action taken regarding the complaint should be communicated to the
complainant as soon as possible.

11.5. Whether the complaint is dealt with through amicable resolution, or where further investigation
was required, the result of the complaint investigation will be explained to the complainant before a final
letter is sent. This allows the complainant to ask any questions and discuss anything that he or she
believes to be outstanding. The explanation should address the complainant’s allegation(s) and
concerns, and the reasoning behind any decision taken. The explanation should also include any action
to be taken as a result of the complaint.

11.6. The letter must reassure the complainant that the complaints have been dealt with fairly and,
where necessary, that action will be taken to ensure there is no re-occurrence of the issue in question.

11.7. Where the complainant expresses dissatisfaction with the outcome of his/her complaint it shall be
made clear to the complainant that nothing further can be done by the Police.

11.8. One of the most effective ways to diffuse a situation, or to prevent a situation from escalating to a
point where a complainant's conduct becomes unreasonable, is to offer a full apology where this is
warranted. An apology should always be given where things have gone wrong, either verbally or in
writing. Any apology should be unambiguous and sincere. The most appropriate form and method of
communicating an apology will depend on the circumstances of the case. In general terms, the most
effective apologies incorporate the following key elements:

11.8.1. Recognition:
a) Description of the wrong - the problem, act or omission to which the apology applies.

b) Recognition of the wrong - an explicit recognition that the action or inaction was incorrect,
wrong, inappropriate, unreasonable or harmful.

c) Acknowledgement of the harm - an acknowledgement that the affected person has suffered
embarrassment, hurt, pain, damage or loss.

11.8.2. Responsibility:
Acceptance of responsibility - taking responsibility for the wrong and harm caused.

11.8.3. Reasons:
Explanation of the cause - a simple, plain English explanation of the reasons for or cause of
the problem.

18
11.8.4. Regret:
a) Apology statement - an expression of sincere sympathy, sorrow or remorse, and a statement
that the action or inaction was wrong or, at the very least, an expression of regret.

b) Sincerity of communication - an important indicator of the level of regret of the person doing
the apologising.

11.8.5 Redress
a) Action taken or proposed - a statement of what has been or will be done to address the
problem.
b) Promise not to repeat - an indication that the action or inaction will not happen again.

11.8. 6. Release
Request for forgiveness - a request to be released from blame (an optional extra to a full and
complete apology).

11.9 Promoting Learning and Accountability

12.1. Organisational Learning:
The key objective of having a public complaints bureau is to promote a culture of continuous learning
that measures current performance, assess public expectations and improve service delivery. In the
course of investigating complaints, opportunities may arise that may require improvements in service
delivery and prevention of persistent and repeated complaints. Learning can include changes to current
practices and policies or can involve the need for training of personnel. It is equally important that
identified good practices are cascaded through the police force to promote lessons learned. In which
case any organisational or individual learning should be clearly documented and forwarded to the
appropriate department or unit to ensure lessons learned are taken forward and considered for future
action.

12.2. Accountability and Transparency:

The complaints handling process also addresses one of the key elements of oversight for policing by
creating a process through which the voice of citizens and communities can be heard and can be
appropriately responded to by the police. It achieves this in two ways. First, it provides the Police with
an efficient, transparent procedure for how to be accountable, and for managing complaints so that they
are effectively dealt with. Secondly, it provides the public with clear guidance on what can be expected
from the police in terms of service and response to complaints, either those made directly to the Police
by citizens, or those made to police oversight agencies.

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 APPENDIX A: Handling Unreasonable Conduct
S/N Conduct Category Unreasonable Conduct
1 Unreasonable Unreasonable persistence includes:
persistence Persisting with a complaint even when it
has been comprehensively dealt with by the
PCB, and all avenues of review have been
exhausted.
Reframing a complaint so that it is
investigated again.
Showing inability to accept the final
decision.
Insisting that the proffered solution is the
correct one in the face of valid contrary or
alternative arguments.
Persisting in interpreting the law or policy in
a way that is not in accordance with
generally accepted views on the issue and
insisting that action be taken accordingly.
Persisting in wanting to know where to go
next, when it has been explained that there
is nowhere to go.
Demanding a review because it is
available, but not arguing a case for a
review.
Making an issue out of anything
Handling Strategies
Communicating clearly and
transparently — e.g. telling
complainants firmly that
something is ‘not going to
happen'.
To the 'where-do-l-go-to-now'
question, telling complainants
that not all problems have an
institutional solution and they
may have reached the end of
the line, unless a realistic
referral can be made.
Requiring complainants who
want a review to provide an
argument for one — e.g. to tell
the police how it has erred or
provide new information — and,
if they don't, their file will remain
closed.
Providing one review only.
Maintaining a ‘no means no’
stance following review.
Adopting, when appropriate, a
firm no-further-correspondence
or contact stance and requiring
any variation from this to be
authorised at a high level
Not allowing complainants to
reframe the complaint to re-
enter the process, unless they
raise new and important issues.
Ending telephone calls that are
unproductive
Managing unreasonable
persistence also includes:
Managing expectations from the
beginning, including ensuring
initial expectations are realistic.
20

2 Unreasonable Unreasonable demands include:
demands Insisting on outcomes that are unattainable.
Insisting on a 'moral' outcome - e.g. justice
in the community interest, when really a
personal interest is at stake.
Demanding an apology or compensation
when no reasonable basis for expecting
such outcomes exists.
Wanting revenge, retribution.
Wanting what is not possible or appropriate
- e.g. copies of sensitive documents,
names and contact details of police officers,
other complainants or informants.
Issuing instructions and making demands
about how a complaint should be handled.
Providing supporting details that are
extraordinarily detailed when such detail is
not relevant to the complaint.
Making unreasonable resource demands,
out of proportion to the seriousness of the
issue.
Wanting regular and lengthy phone contact
where this is not warranted.
Showing reactions or demand for action
that are out of proportion to the significance
of the issue.
Moving the goal posts - changing the
desired outcome.
Shopping for a sympathetic ear in the
PCB/Police Hqt - demanding to talk to a
senior officer.
Adopting a firm and authoritative
communication style both in
writing and verbally.
Defining key issues and keeping
the focus on them.
Letting complainants know in
advance how the Police intends
to deal with the complaint -
having a plan and sticking to it.
Making sure the complainant is
clear that the Police decide how
the complaint should be
handled.
Clarifying the limitations of the
PCB process.
Avoiding being drawn into
hypothesizing, catastrophizing,
conspiracy theories,
unproductive argument and
personal attacks more
generally.
Restricting contact to defined
times and PCB officers where
necessary.
Responding only to emails and
mail addressed to the PCB or
Police directly - not responding
to mail where the PCB is copied
in.
Ending telephone calls that are
unproductive.
Limiting contact to writing only.
Not doing for unreasonably
demanding complainants
something the PCB would not
normally do for any other
complainant, just to appease
them.
21
 Placing the PCB/Police Hqt on an extensive
email copy list and expecting responses to
these emails.
Consistently creating complexity where
there is none.
Presenting as overly needy or dependent -
e.g. wanting to transfer responsibility for
their wellbeing to the PCB.
3 Unreasonable lack of Unreasonable lack of cooperation
cooperation includes:
Presenting a large quantity of information
which is not organised, sorted, classified,
summarised, where the complainant is
clearly capable of doing this.
Presenting information in dribs and drabs -
refusing to present all information at the
outset.
Refusing to define issues of complaint –
‘the attached (usually a large amount of
information) speaks for itself' - where the
complainant is clearly capable of doing this.
Focusing on principles rather than
substantive issues.
Changing the complaint and raising new
issues while the complaint is in the process
of being considered.
Displaying unhelpful behaviour - e.g.
withholding information, being dishonest,
misquoting others, swamping the PCB with
documents.
As a last resort, informing the
complainant that the PCB finds
their interactions unreasonably
demanding and setting defined
limits for further contact.
Managing unreasonable
demands also includes:
Managing expectations from the
beginning, including ensuring
initial expectations are realistic.
Adopting a firm and authoritative
communication style both in
writing and verbally.
Defining key issues and keeping
the focus on them.
Requiring complainants to
organise or summarise the
information they have provided
before the PCB will look at the
complaint (where they can apply
this).
Requiring complainants to
define what their issues are or
to pursue further inquiries
before the PCB will look at the
complaint.
Telling complainants that the
PCB will not look at their
complaint until all the
information has been presented.
Ending the PCB's involvement
in the complaint if it is
discovered that the complainant
has been willfully misleading or
untruthful in a significant way.
Managing unreasonable lack
of cooperation also includes:
Managing expectations from the
beginning, including ensuring
initial expectations are realistic.
22

4 Unreasonable Unreasonable arguments include:
arguments Holding irrational beliefs - e.g. seeing cause
and effect links where there are clearly
none.
Holding what is clearly a conspiracy theory
unsupported by any evidence.
Interpreting facts in a clearly
irrational/unreasonable way and insisting
this interpretation is the correct one.
Arguing the clearly bizarre.
Insisting on the importance of an issue that
is clearly trivial.
5 Unreasonable Unreasonable behaviour includes:
behavior Displaying confronting behaviour - e.g.
rudeness, aggression, threats or
harassment.
Sending rude, confronting or threatening
letters.
Making threats of self-harm.
Making threats of harm to others.
Displaying manipulative behaviour - overly
ingratiating, tears or veiled threats.
Adopting a firm and authoritative
communication style both in
writing and verbally.
Defining key issues and keeping
the focus on them.
The strategy for dealing with
unreasonable arguments in
complaints is primarily about
declining or discontinuing the
PCB's involvement.
These complaints need to be
declined at the beginning or
discontinued as soon as it
becomes clear that the
complaint is groundless.
Alternatively, if unreasonable
arguments are mixed with
reasonable arguments, the
strategy should be to refuse to
deal with the unreasonable
portion.
The strategies for dealing
with unreasonable behaviour
are primarily about 'saying no'
to unacceptable behaviour
and setting limits and
conditions for future
interactions.
Overt anger, aggression and
threats in person, on the
phone or in writing are never
acceptable.
Also:
Return letters framed in rude
and intemperate language and
request that the complainant
reframe their concerns in more
moderate language.
Point out that more moderate
language is clearer and
therefore more likely to achieve
better outcomes.
23
End telephone calls and
interviews if the complainant
becomes abusive and
confronting.

24
APPENDIX B
Nigeria Police Force
Public Complaints Bureau
Case Management Checklist

Casefile Number

Date complaint received

Name of Complainant

Name of PCB Investigator

Date case closed

25
 Yes No Comments

Acknowledgement sent to
complainant

Notification sent to Police Officer

complaint against

Case referred to PCB

Investigator

Case referred to CID

Investigator

Case referred to SERVICOM

Investigator

Request sent to complainant for

relevant documents

Relevant document received

from complainant

Statements taken from

complainant

Decision letter sent to

complainant

Casefile sent for orderly room

trial

26
Public Complaints Bureau
Case Assessment Checklist

Date complaint received

Name of complainant

Address of complainant

Email of complainant

Telephone number of complainants

Summary of the Complaint

Are there grounds to carryout Yes No

urgent investigation?

Case Handling

Yes No Comments

Complaint recorded, incident and

casefile number allocated?

Number of allegations within the

complaint

Number/ Type of Complaint Allegations:

Assault and police brutality

Excessive use of force

Insubordination or Incivility

Neglect of duty

27
Unlawful arrest or detention

Discriminatory behaviour

Corrupt practice

Disorderly conduct

Abuse of power

Breach of confidence

Police involvement in criminal

activity

Suppression of complaints

Unlawful and unnecessary exercise

of authority

Other – criminal

Other – non-criminal

Yes No Comments

Complaint referred to PCB

Complaint referred to SCID

Complaint referred to SERVICOM

Complaint referred for Orderly Room

Trial

Acknowledgement issued to
complainant

Case Progression

Yes No

Complaints investigated by PCB

Investigation Officer?

Number of complaints allegations

disposed of?

No action taken?

Outcome of investigation considered

and agreed?

28
Final response letter issued?

Case referred to SCID?

Case referred to SERVICOM?

Complaint Allegations disposed of:

Complaints withdrawn by
complainant?

Complaint abandoned due to non-

cooperation of complainant?

Complaint unsubstantiated by
available evidence?

Complaint resolved by explanation to

complainant?

Complaint resolved by with resolution

with complainant?

Complaint leading to criminal

proceedings?

Complaint leading to Orderly Room

proceeding?

Complaint Allegations disposed of:

All criminal allegations

Action taken?

Unsubstantiated?

Resolved?

Withdrawn?

Abandoned?

All non-criminal cases

Action taken?

Unsubstantiated?

Resolved?

Withdrawn?

Abandoned?

29
Quality of service allegations received

Policy/ procedure

Service delivery

Organisational decisions

Policing standards

Disposed of?

Any other relevant information

Complaints Timeline Log

Casefile number

Name of Complainant

Name of Officer complaint against

Date From To Details

30
 Flow Chart for the Complaints Process for the Public Complaints Bureau (PCB)

Verbal Complaints
Written Complaints
Public Complaints Complaints received by the Officer in Charge PCB
Bureau (PCB) Unit
All complaints received should be recorded (including verbal complaints received via call, text,
media etc.) should be maintained in writing and filed with unique numbering

All complaints to be assessed within 3 to 5 days of receipt except complex or criminal cases.

Where established that the complaint does not fall within the responsibility of the PCB, it shall be
accepted and acknowledged within 3 days and forwarded to the appropriate unit.

All complaints against the quality of Criminal Complaints of Police Non -Criminal Complaints of Police
service rendered by a Police Officer, Officers Officers
Department, Unit or Station shall be ‘’On Duty” “On Duty”
reported to the SERVICOM Unit “Off Duty” “Off Duty”

The Crime will be The Police Officer Such cases should The PCB officer in
referred to State shall be treated like asses the case for charge shall review the
CID for any member of the determination of the complaint to
investigation public. It should be misconduct determine if mediation
reported and or investigation should
investigated in be carried out
NOTE: Where the complaint is accordance with the
nature of the
considered as non-criminal it shall be criminality involved
referred to the Police SERVICOM for After a thorough and conclusive
investigation. But where it is investigation, the PCB Officer shall carry
established that the police formation is out an objective analysis of the evidence
engaging in criminal activities, the CP gathered and in concluding of
shall immediately be informed, and the investigation the PCB officer shall write a
complaint referred to the CID for report to the Commissioner of Police
investigation outlining the key points of the
complaints and provide supporting
information or evidence, for
consideration by the Commissioner.
 SUPPORTED BY:

NPP