Ethics and Professionalism

The Chartered Institute of Bankers of Nigeria (CIBN) is the umbrella professional body for bankers in Nigeria.

Ethics and Professionalism

Here are the Ethics and Professionalism of the CIBN

The Bankers’ Committee

Code of Conduct in the Nigerian Banking Industry

Bankers’ Committee, Sub-Committee on Ethics and Professionalism

Profile

Following the growing concerns about unethical and unprofessional practices in the Nigerian banking and finance industry, which are capable of eroding public confidence in the industry, the Governor of the Central Bank of Nigeria (CBN) articulated the urgent need for operators to take steps to combat the emerging menace.

In line with the provisions of the applicable laws, the Governor sought the co-operation of the banks through the Bankers’ Committee.

The Bankers’ Committee

The Bankers’ Committee, in its determination to sanitize the practice of banking and finance in Nigeria and instil discipline in the profession, established the Sub-Committee on Ethics & Professionalism on 19th December 2000. The mandate of the Sub-Committee was to:

Identify practices and conducts considered unethical in the industry
Develop an acceptable code of ethics and professionalism and put in place effective machinery for enforcing compliance.

The Sub-Committee, made up of 15 members, began its work of soliciting memoranda from all the banks and financial institutions in Nigeria, in addition to a Discussion Paper from Chief (Dr.) J. O. Sanusi, FCIB, the then Governor of CBN.

It thereafter synthesized the inputs and following several working sessions, arrived at this Code. The Code contains a list of acts, conducts, commissions and omissions classified as unethical and unprofessional as well as the framework for addressing these in the business of banking and finance in Nigeria.

Thus, the Code also provides the procedure for dealing with complaints and the sanctions for infractions of its provisions.

Objectives Of The Code Of Ethics

The overall objective of the Code of Conduct in the Nigerian Banking Industry is to ensure strict adherence to best banking practices and a strong commitment to ethical and professional standards in behavior within the Nigerian banking industry.

This Code of Conduct applies to all Directors, Managers, Officers, Supervisors, and Employees including full-time, part-time, temporary, casual, and in-sourced staff of all banks/Discount Houses in Nigeria. All are expected to read the Code carefully and commit to its letter and spirit.

The Code defines for financial institutions, regulators, bank employees, and members of the Institute, acts and practices considered unethical or unprofessional, along with the corresponding sanctions for non-compliance.

The Central Bank of Nigeria’s Circular BSD/BCS/GEN/DBS/05/095 dated July 25, 2014, mandates all bank and financial institution staff to complete the Attestation Form. Click here to access the Attestation Form. Staff are expected to read and understand the Code’s provisions and complete the form. A downloadable copy of the Code is attached and available here.

The Sub-Committee on Ethics and Professionalism

Objectives of the Sub-Committee

To ensure the highest level of adherence to sound and generally accepted banking practice.
To ensure a strong commitment to good banking practice.
To uphold the integrity of the banking profession in order to instill public confidence in the banking system.

Duties of Sub-Committee

To develop standard and codes for ethical and professional banking practice.
To consider complaints from bank customers, the general public and from within the banking system.
To consider complaints by banks against the regulatory authorities or other banks and vice versa.
To consider complaints from bank staff against their employers or vice versa.
To cause enforcement of decisions approved by the Bankers’ Committee.

Membership and Governance

The Sub-Committee consists of representatives from:

CBN (Banking Supervision and Consumer Protection Departments)
NDIC (Bank Examination Department)
Seven Bank Managing Directors (appointed for a four-year terms)
CIBN (acting as the Secretariat)

Secretariat Of The Sub-Committee

The Chartered Institute of Bankers of Nigeria, Ethics and Professionalism Division performs the Secretariat functions of the Sub-Committee. The Registrar/Chief Executive is the Secretary, Sub-Committee on Ethics and Professionalism.

Procedure For Handling Cases

Petition Submission
- Petitions must be submitted in two hard copies, with an electronic version.
- The complaint form must be duly completed and submitted along with a non-refundable N100,000 filing fee.
- All petitions must be registered and include proof of prior engagement with the bank.
Response and Documentation
- Banks must respond within two weeks or within a period determined by the Sub-Committee.
- If additional time is required, the Sub-Committee may grant an extension. Otherwise, a decision will be made based on available information.
Review and Resolution
- Once a resolution is confirmed by both parties, the case is closed.
- Disputes are resolved through:
  - Mediation meetings with both parties and the Investigating Panel.
  - Oral interviews/investigations conducted by the Investigating Panel.
  - Technical Team reviews for excess charges or unresolved mediation issues.
  - Court-referred cases, where applicable.
Restrictions and Penalties
- Banks are prohibited from taking a pending case before the Sub-Committee to court.
- Authorized representatives of petitioners and respondents must attend proceedings to authenticate agreed positions.
Particulars of Claims
- Petitions must include a brief summary with referenced supporting documents.
- Authorized agents of the complainant must provide a letter of mandate/appointment from the complainant.
Relief/Claims Sought
- Claims must be clearly stated with the period of infraction.
- New claims cannot be introduced after submission.
- The expected refund amount must be summarized.
Confidentiality and Media Restrictions
- Parties are strictly prohibited from discussing cases in the media while under review by the Sub-Committee.
- Breaches of confidentiality will result in sanctions.
Communication and Enforcement of Decisions
- Both parties will receive formal written notice of the Bankers' Committee's ratified verdict.
- If a refund is required, the bank must pay the amount (including interest and penalties) within 14 days.
- A 14-day grace period may be granted via a reminder.
- Failure to comply will result in CBN debiting the bank's account, plus a 1% penalty for non-compliance.
Interest Application on Refunds
Where a refund is required, interest shall be applied as follows:
- Facility accounts: Maximum lending rate of the bank for the period of infraction.
- Non-facility accounts: Maximum lending rate of the bank for the period of infraction.
- Recouped funds by banks will not attract interest.
Appeal Process
Parties may appeal a decision upon full compliance of the following conditions:
- Appeals must be filed within 30 days of the decision—late appeals will not be entertained.
- If the ruling involves payment, the bank must deposit the decision amount with the Sub-Committee.
- Appeals must include a N500,000 fee (N250,000 non-refundable filing fee + N250,000 caution fee, refundable if successful).
- Supporting new documentary evidence must be provided.
- The Investigating Panel of the Sub-Committee will review the case based on the new information.

Scope of Work

Jurisdiction of the Sub-Committee

The Sub-Committee adjudicates cases involving:

Disputes between banks and customers
Disputes between banks
Petitions from regulators against banks and vice versa
Cases referred by courts
Cases transferred from CBN, NDIC, or other regulators

Matters Not Handled by the Sub-Committee

The Sub-Committee does not handle:

Infractions older than six years
Cases below N5 million in value
Cases before courts (unless referred by a court order)
Cases under CBN review or previously ruled upon by CBN or regulators (except when requested for review)
Claims without a customer mandate
Criminal allegations or damages claims
ATM and electronic banking disputes
Cases previously adjudicated by the Sub-Committee (except on appeal)
Cases where debts have been acquired by AMCON

Powers of the Sub-Committee

The Sub-Committee has the authority to:

Investigate and adjudicate cases, including inviting parties, witnesses, and obtaining documents.
Make decisions and recommendations on cases, including accepting or declining jurisdiction.
Collaborate with individuals or organizations for investigations.
Manage financial transactions, including receiving and disbursing funds.
Control proceedings, including restricting observers when necessary.
Sanction member institutions and employees, where applicable.

Membership and Governance

The Sub-Committee consists of representatives from:

CBN (Banking Supervision and Consumer Protection Departments)
NDIC (Bank Examination Department)
Seven Bank Managing Directors (appointed for four-year terms)
CIBN (acting as the Secretariat)

The Chartered Institute
of Bankers of Nigeria