- 20 Marks
Question
Responsible Banking is central to strategies of banks recovering from financially distressed economies and financial sectors. Critically examine the governance framework that the Board of Goodbank Plc in Ashland should institutionalise to enforce responsible banking practices.
(25 marks)
Answer
With my background in risk and compliance at major Ghanaian banks like Access Bank Ghana, where I navigated post-2019 cleanup towards sustainable practices, responsible banking integrates ESG (Environmental, Social, Governance) under BoG’s Sustainable Banking Principles (2019) and aligns with global standards like UN Principles for Responsible Banking. In distressed contexts like Ghana post-DDEP (2022-2024), where fiscal strains led to bond losses, boards must institutionalize frameworks to prevent failures (e.g., Capital Bank’s governance lapses) and promote triple bottom line: economic, social, environmental. This enhances public trust, per BoG Corporate Governance Directive, and avoids bailouts.
Critically examining the framework:
- Establish a Responsible Banking Policy and Oversight Structure (5 Marks): Board-approved policy integrating ESG into strategy, with a dedicated committee (e.g., Sustainability Committee) reporting quarterly. Critically, this ensures ethical leadership, avoiding nepotism or conflicts as per Code of Ethics.
- Embed Risk-Based Compliance and Due Diligence (5 Marks): Incorporate KYC and AML/CFT under Act 749, extending to ESG risks (e.g., IFC Exclusion Lists for lending). In Ghana, post-DDEP, banks like Fidelity assess climate risks in portfolios, mitigating non-compliance costs.
- Promote Ethical Training and Culture (5 Marks): Mandatory training on fiduciary duties, whistleblowing per BoG Directive. Critically, this counters corruption, drawing from Enron’s ethical failures, and local cases like Meridian BIAO.
- Enhance Disclosures and Stakeholder Engagement (5 Marks): Voluntary IFRS sustainability reports and multi-stakeholder dialogues (e.g., with SEC, GSE). Example: GCB Bank’s 2024 ESG reports post-recovery built confidence.
- Monitor Performance with KPIs and Audits (5 Marks): Use metrics like social impact loans ratio, audited by internal functions. Critically, this aligns with Basel III, ensuring adaptability in distressed economies for long-term profitability.
This framework institutionalizes responsibility, fostering resilience and ethical practices in Goodbank Plc.
- Topic: Sustainable Banking Principles
- Series: APR 2023
- Uploader: Samuel Duah