Code of Conduct

Code of Conduct Policy

Suma Rural Bank – April 2025 · Version 1.0
Prepared By: The Board of Directors

Introduction

This Code of Conduct Policy sets out the ethical, professional, and legal standards expected of all individuals working with or for Suma Rural Bank Plc. It incorporates key provisions from the Ghana Banking Code of Ethics and Business Conduct (Chartered Institute of Bankers, Ghana) and aligns with applicable laws and regulations.

1A. Definitions

Conflict of Interest: A situation where personal interest could interfere with professional duties or decisions.
Confidential Information: Any non-public information relating to customers, staff, strategies, or operations of the Bank.
Misconduct: Any behavior that violates the Bank’s Code, policies, or laws or puts the Bank’s name into disrepute.
Gifts: Items or services received from third parties that may influence decisions.

Objectives

Promote ethical behavior and integrity in banking practices
Ensure compliance with laws, regulations, and internal policies
Foster professionalism, fairness, and transparency
Safeguard the interests of customers, staff, regulators, and shareholders

Scope

This Code applies to:

Board members and executive management
All permanent and temporary staff
Interns, consultants, agents, vendors, and outsourced personnel

Core Ethical Principles

Integrity: Act with honesty, good faith, and transparency.
Objectivity: Make unbiased decisions based on facts.
Confidentiality: Safeguard confidential information.
Professionalism: Demonstrate competence, diligence, and respect.
Accountability: Take responsibility for actions and decisions.
Compliance: Observe all applicable laws, codes, and Bank of Ghana directives.

5. Professional Conduct Requirements

5.1 Ethical Behavior

Avoid actual or perceived conflicts of interest
Do not solicit or accept bribes, kickbacks, or inducements
Conduct business with fairness and in good faith

5.2 Workplace Conduct

Treat all individuals with respect and fairness
Avoid discrimination, harassment, bullying, or abusive conduct
Promote a safe, diverse, and inclusive work environment

5.3 Sexual Harassment

Suma Rural Bank maintains a zero-tolerance policy toward sexual harassment. This includes unwelcome advances, inappropriate touching, or any verbal or physical conduct that creates a hostile work environment. Employees must report such behavior immediately to HR or via whistleblowing channels.

5.4 Appearance and Representation

Dress and behave professionally at all times
Obtain management approval for public statements or media appearances

5.5 Gifts and Benefits

Do not accept or give gifts intended to influence decisions
Declare any gift above GHS 200 to the Compliance Unit
Promotional gifts of limited value may be accepted with discretion

5.6 Use of Bank Resources

Use bank assets responsibly and only for official duties
Report any misuse, theft, or loss of resources immediately

6. Confidentiality and Data Protection

Uphold customer and institutional confidentiality
Disclose information only when legally required
Comply with the Data Protection Act, 2012 (Act 843)

7. Conflicts of Interest

Disclose personal interests that may affect professional judgment
Avoid activities conflicting with the Bank’s objectives
Refrain from using position for personal advantage

7A. Romantic or Marital Relationships in the Workplace

Employees in romantic or marital relationships with colleagues must disclose to HR to prevent conflicts of interest or power imbalance. Such relationships must not influence workplace decisions or promotions.

8. Insider Abuse and Misuse of Information

Do not exploit confidential or insider information for personal gain or unauthorized disclosure.

9. Misleading Conduct and Reporting

Do not file false regulatory reports
Avoid misrepresentation in advertising or customer communication
Ensure fairness in market conduct and product disclosure

10. Regulatory Compliance and Legal Obligations

Anti-Money Laundering Act, 2020 (Act 1044)
Whistleblower Act, 2006 (Act 720)
Banks and SDI Act, 2016 (Act 930)
Bank of Ghana and other regulatory directives

11. Whistleblowing and Reporting Misconduct

Employees are encouraged to report unethical practices
Anonymous reporting channels are available
Whistleblowers are protected from retaliation under Act 720

12. Customer and Market Conduct

Treat customers fairly and professionally
Provide accurate information and resolve complaints promptly
Avoid undisclosed fees or product misrepresentation

13. Handling of Disputes and Grievances

Steps to resolve grievances within the Bank:

Informal Resolution: Attempt to resolve issues directly with the person/unit involved.
Formal Complaint: Submit to HR, Compliance, or relevant department with details and documentation.
Preliminary Assessment: Response within 2–5 working days to determine severity and escalation.
Investigation: Managed by relevant committee ensuring confidentiality.
Resolution: Written decision issued within 10 working days of review.
Appeal: Escalate to CEO or Board Chair within 5 working days if dissatisfied.
Documentation: All records kept confidentially by HR or Compliance.

14. Disciplinary Measures

Verbal or written warnings
Suspension, demotion, or termination
Legal prosecution where applicable

14A. Sanctions for Directors

Outlined procedures for reporting, investigation, and sanctioning of Board members found in breach of the Code.

14B. Sanctions for the Chief Executive Officer

Allegations against the CEO are handled by the Board through an Adhoc Investigative Committee, ensuring due process and regulatory reporting.

14C. Disciplinary Procedure for Staff

Structured steps for reporting, investigation, and sanctioning staff misconduct, including appeal rights and documentation.

14D. Third-Party Code of Conduct Compliance Clause

All consultants, vendors, and agents must comply with the Bank’s Code of Conduct. Breaches may lead to contract termination, withholding payments, or legal referral.

15. Responsibilities

Board of Directors: Oversight and policy approval
Executive Management: Enforcement and monitoring
Compliance Unit: Training, monitoring, and investigation
All Employees: Adherence and ethical behavior

15A. Digital Conduct and Social Media Use

Employees must avoid posting offensive or confidential content related to the Bank. Official communications must be approved by Management.

15B. Sustainability and Ethical Governance

Suma Rural Bank is committed to responsible and sustainable operations. Employees must support ethical governance principles.

16. Review and Amendment

This policy shall be reviewed every two (2) years or earlier as required by regulation or internal changes.

17. Acknowledgment

All employees must sign the Code of Conduct Acknowledgment Form upon onboarding and renew it annually.

18. Stakeholder Code of Conduct Acknowledgment Form

Contractors, vendors, and agents must affirm compliance with the Bank’s Code, maintain confidentiality, and uphold ethical conduct.

Policy Adoption

This policy has been considered and approved by the Board on 26th April 2025.

Signed:
Chief Executive Officer ___________________________
Chairman, Board of Directors ___________________________
Date: 26/04/2025

Version 1.0
Prepared By: The Board of Directors