At the 2020 Annual Bankers’ Dinner (Governor’s Day), organized by the Chartered Institute of Bankers, Ghana (the Institute) on Saturday, November 28, 2020, the President of the Institute, Patricia Sappor, FCIB, together with the Governor of the Bank of Ghana, Dr. Ernest Addison, FCIB and his Deputies and the CEO of the Ghana Association of Bankers, Mr. John Awuah launched the Ghana Banking Code of Ethics and Business Conduct.

The Code serves as a guide to all members and practitioners in meeting their obligations to customers and other relevant Stakeholders.

This is in line with Section 3(d) of the Chartered Institute of Bankers Ghana, Act 2019 (Act 991) which mandates the Institute to set standards and ensure the observance of ethical standards and professional conduct among members of the banking profession in the country.

The Code applies to all practitioners and professionals in the banking industry in Ghana as well as members of the Institute per Section 14 of (Act 991).

The Code is to be read along with all relevant Bank of Ghana Directives, Notices and Circulars, Ghana Association of Bankers (GAB) Code of Business Conduct, and where applicable the Code of Conduct of Banks and Financial Institutions regulated under Banks and Specialised Deposit Taking Institutions Act, 2016 (Act 930) and Non-Bank Financial Institutions Act, 2008 (Act 774).

The objective of the Code

The principal objective of the Code is to ensure strict adherence to best banking practices and maintain high ethical and professional standards within the banking industry in Ghana. The objectives include: 

1. Maintenance of excellent standards of service, performance and quality of banking products;
2. Compliance with applicable laws and regulations;
3. Avoidance of potential conflict of interests;
4. Exhibiting objectivity, fair-mindedness, honesty and integrity in the performance of their duties in both official and informal capacities to uphold mutual trust and public confidence;
5. Maintenance of best banking practices and strong commitment to sound, ethical and professional standards in the banking industry;
6. Provision for the rights and obligations of Members,
7. Promotion of banking services as an instrument of economic growth, and
8. Provision of framework for gift policy.

The Scope of the Code

The Ghana Banking Code of Ethics and Business Conduct (Code) exhaustively covers the following four areas:

1. Professional Code of Conduct for Members
2. Financial Institutions and their Customers
3. Inter-Bank Relationships
4. Financial Institutions Obligations to Bank of Ghana and Other Relevant Regulators

1. Professional Code of Conduct for Members

The Code covers important subject areas such as Integrity requiring members and practitioners to act with professionalism, honesty and in truth, and to relate with Stakeholders in good faith and avoid taking advantage of their position for their personal benefits. It also considers objectivity and independence. It is expected thatin the performance of professional duties and obligations members and practitioners shall be objective and not make decisions based on personal beliefs, biases or prejudices.

Members and practitioners are expected to have relevant knowledge, skill, competence and exhibit reasonably expected professional conduct as well be abreast with all new developments in the banking industry through continuous professional education.

Furthermore, members and practitioners should be conversant with all relevant laws and regulations relating to banking and Bank of Ghana Notices, Guidelines and Directives and act with due skill, care and diligence in performance of their duties and obligations.

Members and Practitioners also have the responsibility to keep confidential any information or data that they may have access to in the course of exercising their professional duties. Employers are to ensure access to confidential information is restricted to only employees requiring such information for the performance of their duties.

The Code enjoins practitioners to ensure that major irregularities observed in the work place are reported to designated officers in line with the Organization’s policies. Employers are also expected to notify the Institute, in the event a member or practitioner who is an employee, is involved in acts of professional misconduct.

The Code implores members to be accountable to their Employers, Customers, Regulatory Authorities, the Institute and the general public.

2. Financial Institutions and their Customers

Among other things, Financial Institutions are to establish standards of acceptable banking practice which are to be followed in dealings with customers and other consumers; conduct business in the best ethical and professional manner consistent with global best practice; observe and demonstrate proper standards of market conduct at all times; provide information on products and services and potential risks to customers; maintain and sustain public trust and confidence in the financial system; operate within the statutory, legal and regulatory framework; always meet commitments to customers; conduct due diligence on prospective customers; inform customers of the various communication channels through which all forms of information can be conveyed to them; inform  customers of all financial transactions in their accounts; and display fairness and transparency in the conduct of their business and relationship with other parties.

3. Relationships

The Code strongly recommends that Financial institutions, at all times and as expeditiously as possible, conduct due diligence to ascertain the credit-worthiness of other financial institutions before engaging in inter-bank transactions; accord priority to inter-bank obligations; collaborate with other operators, regulators and the Institute to keep the financial industry sanitized. The Code additionally prevents Financial Institutions from hiring a person that has been found guilty by a Court of Competent jurisdiction or whose appointment has been terminated or has been dismissed for fraud and/or other criminal, unethical and professional misconduct in other Financial Institutions.

4. Financial Institutions Obligations to Bank of Ghana and Other Relevant Regulators

Financial Institutions are to be cooperative and transparent with relevant Regulatory Authorities and comply with all regulations and legal requirements to provide adequate information on all issues as may be required by Bank of Ghana and other regulatory bodies.

5. Infringements and Sanctions        

Any member or industry practitioner whose activities contravene any provision of the Code shall be sanctioned by the Council of the Chartered Institute of Bankers, Ghana in accordance with Sections 22 (c) and 24 (1) (a) of Act 991.

6. Enforcement of the Code of Conduct

The Institute will count on the assistance and co-operation of all members in the industry for effective enforcement of the Ghana Banking Code of Ethics and Business Conduct. 

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The writer is the President of the Chartered Institute of Bankers, Ghana