Whistleblowing Policy

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

1. Purpose and Scope

This policy encourages and protects individuals who report suspected acts of impropriety, wrongdoing, or unethical conduct at Suma Rural Bank Plc. It ensures safe and structured reporting in compliance with the Whistleblower Act, 2006 (Act 720) and its amendment. It applies to all employees, directors, agents, contractors, customers, suppliers, and stakeholders.

2. Definitions

Impropriety includes but is not limited to:

Fraud, theft, bribery or corruption
Financial mismanagement
Breach of banking regulations or internal controls
Health or safety risks
Environmental hazards
Abuse of power or authority
Any act that is criminal or unlawful under Ghanaian law

3. Eligible Whistleblowers

Any of the following may raise a concern:

Staff and officers of the Bank (permanent, contract, or temporary)
Customers, suppliers, and other external stakeholders
Members of the general public with credible information

4. Reporting Channels

4.1 Internal Reporting Lines

Whistleblowers are encouraged to first report concerns through internal channels:

Immediate Supervisor or Department Head
Compliance Officer
Head of Internal Audit
CEO
Email: whistleblower@sumaruralbank.com

4.2 External Reporting Authorities

If internal reporting is not appropriate or effective, whistleblowers may report directly to:

Bank of Ghana (Rural and Community Banks Division)
ARB Apex Bank Plc
CHRAJ
Office of the Special Prosecutor
Attorney-General’s Department
Ghana Police Service
Parliament of Ghana
Auditor-General’s Department

BoG may be contacted through its Market Conduct Office or Consumer Reporting Channels.

5. Confidentiality and Protection

All whistleblower identities and reports are treated with strict confidentiality.
Reports may be made anonymously; however, detailed information aids investigations.
Whistleblowers acting in good faith are protected from retaliation or harassment.
Malicious or reckless disclosures may lead to disciplinary or legal action.

6. Investigation Process

Reports are acknowledged within 7 working days.
Investigations are completed within 60 days by the Compliance or Internal Audit Unit.
Matters may be referred to external authorities such as BoG or CHRAJ.
Outcome summaries (where permissible) will be shared with the whistleblower.

7. Whistleblower Rewards

In line with the Whistleblower Act 720 (as amended), whistleblowers whose reports lead to successful prosecution or recovery of funds may receive a monetary reward of up to 10% of recovered sums, determined by the Attorney-General and Inspector General of Police.

8. Record Keeping and Oversight

The Compliance Officer maintains a Whistleblower Register of all reports and actions.
Quarterly anonymized summaries are submitted to the Board Audit & Risk Committee.
The Bank of Ghana may request periodic updates in line with regulatory requirements.

9. Awareness and Training

Suma Rural Bank shall conduct annual staff training on whistleblowing rights, procedures, and protections.

10. Review of Policy

This policy shall be reviewed every two years or earlier if required by legislation or internal risk assessments.

Approval

This policy has been reviewed 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