CODE OF CONDUCT

IN THE NIGERIAN BANKING INDUSTRY

(PROFESSIONAL CODE OF ETHICS
AND BUSINESS CONDUCT)

Published by:
The Chartered Institute of Bankers of Nigeria
Bankers House
PC 19, Adeola Hopewell Street
Victoria Island, Lagos

© Copyright 2014
The Chartered Institute of Bankers of Nigeria

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Printed by:
The CIBN Press Limited
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7, Turton Street, Sabo-Yaba, Lagos

08055314308

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 CONTENTS

ACRONYMS 3
PREAMBLE 4
DEFINITIONS AND INTERPRETATIONS 6
OBJECTIVES 8

SECTION 1
Professional Code of Conduct for Individual Members 10–14

SECTION 2
Unethical Practices/Unprofessional Conduct for
Members 15–23

SECTION 3
Banks and their Customers 24–35

SECTION 4
Infringements and Sanctions 36–50

SECTION 5
Establishment of the Investigating Panel and
Disciplinary Tribunal (Extract from the CIBN Act) 51–53

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CODE OF CONDUCT IN THE NIGERIAN BANKING
INDUSTRY
(Professional Code of Ethics and Business Conduct)

Acronyms:

BBCEN: Body of Banks Chief Executives in

Nigeria
BC: Bankers’ Committee
BCIP: Bankers’ Committee Investigating Panel
BCSEP: Bankers’ Committee Sub-Committee on
Ethics & Professionalism
BOFIA: Banks & Other Financial Institutions Act
CAMA: Companies & Allied Matters Act
CBN: Central Bank of Nigeria
CCCOBIN: Committee of Chief Compliance Officers
of Banks in Nigeria
CCSOB: Committee of Chief Security Officers of
Banks
CIBN: Chartered Institute of Bankers of Nigeria
EFCC: Economic and Financial Crimes
Commission
FIRS Federal Inland Revenue Service
ICPC: Independent Corrupt Practices and
Other Related Offences Commission
NDIC: Nigeria Deposit Insurance Corporation
NDLEA: National Drug Law Enforcement Agency
OFID: Other Financial Institutions Department
SIID: Special Insured Institutions Department
DH: Discount Houses

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1.0 PREAMBLE:
1.1 This Code cannot and does not prescribe behaviour for
every eventuality. The overall objective of this Code is
to ensure strict adherence to best banking practices
and strong commitment to ethical and professional
standards in behaviour in the Nigerian banking
industry.

1.2 This Code of Conduct (the Code) extends to all

Executive Directors, Managers, Officers, Supervisors
and Employees including full-time, part-time,
temporary, Casual and in-sourced employees of all
banks/Discount Houses in Nigeria, who are urged to
read the Code carefully and commit themselves to its
letters and spirit. This Code shall be read along with
the subsisting Chartered Institute of Bankers of
Nigeria Act, Banks and Other Financial Institutions
Act, Central Bank of Nigeria Act; Nigeria Deposit
Insurance Corporation Act; Companies and Allied
Matters Act, and all regulations relating to Banks and
banking business in Nigeria, including Circulars and
Guidelines from CBN and other Regulatory/
Supervisory bodies, Code of Corporate Governance for
Banks in Nigeria, Code of Conduct for Nigeria Deposit
Insurance Corporation, (NDIC) Examiners, Code of
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 Conduct for Central Bank of Nigeria (CBN) Examiners
and Code of Best Practices and Corporate Governance
in Nigeria, as well as Code of Conduct for each
Corporate member of The Chartered Institute of
Bankers of Nigeria.

1.3 A member of the Institute has responsibilities to his

employer, customer, the general public, the
government in Nigeria and the Institute. The Institute
requires its members, as a matter of necessity, to
recognize these responsibilities in the conduct of their
businesses and to strictly adhere to this Code. The
Code provides the procedure for dealing with
complaints of unethical and unprofessional practices
and the sanctions for infractions of its provisions.
Sections 1 and 2 of the Code address issues relating
to individual members, while Section 3 addresses
issues concerning corporate members. Members shall
operate within the statutory, legal and regulatory
framework of the banking industry in particular and
the country in general.

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2.0 DEFINITIONS AND INTERPRETATIONS
In this Code:
a) “Employee” means an individual employed/
appointed/engaged/recruited by any bank or other
institutions within the banking industry in Nigeria.
b) “Employer” means a corporate entity within the
banking industry that engages/hires an individual to
provide services in exchange for remuneration -
salaries/wages.
c) “Institute” means The Chartered Institute of Bankers
of Nigeria.
d) “Member(s)” means individuals and corporate
members of the CIBN and other employees engaged in
the banking industry
e) “Service Provider” means a person (Corporate/
individual) who in consideration of remuneration
received or to be received either by himself or in
partnership with any other person –
i) engages himself in the practice of banking or
holds himself out to the public as a member of
the banking profession; or
ii) renders professional service or assistance in or
about matters or principle or detail relating to
banking procedures; or

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c) renders any other service which may by regulations
made by the Council, be designated as service
constituting practice as a member of the banking
profession.

In this Code, unless the context otherwise requires:

a) References to any gender include all genders

b) Words in the singular shall include the plural and in
the plural include the singular
c) Reference to a statute or statutory provision is a
reference to it as amended, extended or re-enacted
from time to time
d) Reference to statute or statutory provision shall
include all subordinate legislation made from time to
time under that statute or statutory provision
e) Any words following the terms including, include, in
particular or any similar expression shall be
construed as illustrative and shall not limit the sense
of the words preceding those terms.
f) A person includes a natural person or corporate body
and that person’s personal representatives, successors
or permitted assigns
g) The headings in this Code do not affect its
interpretation.

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3.0 OBJECTIVES

This Code of Conduct provides a framework to:

a. Guide every member, both individual and corporate,

in meeting their obligations to customers and other
stakeholders by maintaining and improving standard
of service, performance and quality of banking
products.
b. Ensure that all bank employees shall conduct their
duties fairly and honestly.
c. Maintain the best banking practice and strong
commitment to sound ethical and professional
standards in the banking industry.
d. Guide stakeholders within the banking industry to
comply with applicable laws and regulations.
e. Reaffirm and clarify individual and corporate
members’ rights and obligations.
f. Enable members to provide a policy to develop and
maintain constructive dialogue with, seek assistance
and advice from colleagues when faced with
difficulties in matters of judgement.
g. Enable members to provide a policy to avoid
acceptance of gifts on services arising from performing
their official duties which might influence members’
independent judgement.
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h. Enable members to provide a policy to adhere to
generally accepted principles of honesty, integrity and
fairness so as to uphold the mutual trust and public
confidence bestowed upon them.
i. Enable members to provide a policy to be fair-minded
in their day to day dealings both in office and during
their social interactions. All bank employees are
expected to be committed to high standards of
conduct in daily social life in order to uphold the
dignity, reputation and good standing of the banking
profession.
j. Promote, both individually and collectively, the
efficiency of bank services as an instrument of
economic growth.

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 SECTION 1:

PROFESSIONAL CODE OF CONDUCT FOR

INDIVIDUAL MEMBERS

1.1 Core Principles

A member shall:
i. Conduct himself in relation with customers and third
parties on principles of Honesty, Integrity, Diligence,
Credibility, Transparency, Fairness, and Trust.
ii. In the performance of his professional duties as a
banker, attain appropriate levels of professional
education/certification, training, competence, skill
and expertise.
iii. Advise his customers where necessary without
deliberately misleading them.
iv. Abstain from discrimination but treat all customers
and co-employees equally regardless of age, sex,
religion, ethnicity, status, colour, language, disability,
etc.
v. Exercise care and caution while discharging his
duties.
vi. Abstain from verbal and physical assaults of
customers, co-employees and other stakeholders.

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1.2 Confidentiality/Dissemination of Information
A member shall:
i. Not in the course of discharging his professional
duties, knowingly or recklessly disseminate false or
misleading information to his customers or any other
party.
ii. Not disclose or permit the disclosure to any third
party, any confidential information concerning his
employer’s or his customers’ business during or after
employment except as required or permitted/enjoined
by law, thus:
a. Where a bank is compelled by a court of
competent jurisdiction or regulatory provision
to do so;
b. Where there is a duty to the public to disclose;
c. Where the interest of the bank requires
disclosure; and
d. Where disclosure is made at the request, or
with the consent (express or implied) of the
customer.
iii. Sign a Declaration of Secrecy to bind himself to
confidentiality of information.

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1.3 Conflict of Interest
i. A member shall, at the earliest opportunity, bring to
the notice of his employer, customers, or any third
party, in all cases, where conflicts of interest arise in
the discharge of his duties to such employers,
customers or third party.
ii. Where the terms of service agreement of a member
with his employer are in conflict with this Code, the
provisions of the Code shall prevail.

1.4 Litigation against a member:

i. Prior to the pursuit of any legal redress on civil
matters against an individual member, the institution
(Bank/Discount House) shall first explore all internal
redress processes/procedures within the Institute,
including the Investigating Panel.
ii. No member shall seek redress for any act (perceived or
actual) of wrong-doing on matters relating to the
Institute’s affairs through legal action without first
reporting to and obtaining a response from the
Governing Council of the Institute within a reasonable
period which shall not exceed 90 days from the date of
report.
iii. A member shall be given opportunity to seek redress
in respect of any matter falling within the purview of
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 this Code with his employer through the Institute
before exercising the right to go to the court of law,
where necessary.

1.5 Association

A member shall not knowingly do business with

people of questionable character and integrity.

1.6 Sexual Harassment

i. Members, of either sex, shall not sexually or otherwise

harass each other.
ii. Sexual harassment shall include but not limited to
situations where a member/employee uses or
attempts to use his/her position to seek/obtain sexual
gratification from another who may succumb in fear of
adverse consequences on his/her employment/
business.

1.7 Dressing
Members shall dress in line with the dress code of
his/her institutions without provoking the opposite
sex.

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1.8 Responsibility
i. A member shall act and conduct himself in a
responsible and professional manner at all times.
ii. A member shall ensure that major irregularities
observed in the work place are reported to designated
officers in line with the existing Whistle Blowing Policy
where applicable.
iii. A member shall honour invitations from law
enforcement agents in the course of their investigation
and act as witness in court/alternative dispute
resolution mechanisms when required.

1.9 Accountability
A member shall, in the discharge of his duties, be
accountable to his employers, customers/consumers,
regulatory authorities, governments, the Institute
and the general public.

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 SECTION 2:

UNETHICAL PRACTICES/UNPROFESSIONAL
CONDUCT FOR MEMBERS

Members are expected to maintain high ethical and

professional standards of conduct and practice within and
outside the banking industry. In this connection, therefore,
certain conducts and practices are classified as unethical/
unprofessional for members. These inter alia include but not
limited to the following:

2.1 Conflict of Interest

i. Engaging in activities which compete, interfere with or

constrain an employer’s primary business and
responsibilities.
ii. Colluding with third parties to undermine the
employer’s corporate objectives, for example, inflation
of contracts.
iii. Undermining legitimate earnings/interests of the
employer.
iv. Competing with his employer by offering to third party
the same services/products offered by the employer.

2.2 Abuse of Trust/Office

Abuse of trust/office shall include but not limited to:

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a) Abuse of position and taking advantage of such
position to enrich oneself.
b) Unauthorized use of customers’ names to among
others:
– procure foreign exchange,
– obtain credit facilities,
– initiate contracts,
– transfer funds,
– withdraw funds, etc.
c) Exploiting the ignorance of unsuspecting customers,
through excessive/unwarranted charges (fees,
commissions, etc).
d) Recommending to and/or influencing the employment
of a person proven to be of dubious or questionable
character or doubtful integrity.
e) Knowingly allowing or permitting any fraudulent staff
proven by a court of law or the CIBN Disciplinary
Tribunal to resign.
f) Colluding with customers to:
i. Jeopardize the interest of the employers, e.g.
diversion of credit facilities for unintended/
unapproved purposes.
ii. Compromise or circumvent underlying terms
and conditions or transaction protocol of credit

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 facilities such that the performance of credit
facilities is endangered; etc
g) Granting of Credits above approved specified
limits/approval limit to customers or related party
against statutory/regulatory provisions and corporate
policies.
h) Engaging in fraudulent activities in the course of his
employment.
i) Using his position to initiate a contract and award
same to himself through related parties.
j) Transferring depositors’ funds in his care to other
accounts or persons without appropriate authority.

2.3 Disclosure
a) Lack of appropriate disclosure in dealing with other
players and customers in the market place.
b) Knowingly understating:
– The volume of total deposits on which the deposit
insurance premium payable to the Nigeria Deposit
Insurance Corporation (NDIC) is based;
– Mandatory reserve requirements prescribed by the
Central Bank of Nigeria (CBN).
c) Imposition of undisclosed charges on customers’
accounts without formal advice and agreement.

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d) Imposition of charges and fees alien to Guide to Bank
Charges on customers/consumers
e) Failure to render timely, accurate and complete
returns on dismissed/terminated staff to the Central
Bank of Nigeria (CBN), Nigeria Deposit Insurance
Corporation (NDIC), and Chartered Institute of
Bankers of Nigeria (CIBN).
f) Failure to render timely, complete and accurate
returns on eligible credits, to the CBN for Credit Risk
Management System (CRMS) and Credit Bureaux.
g) Failure to promptly report delinquent credit customers
to the CRMS of the CBN and licensed Credit Bureaux.
h) Failure to provide adequate information on all issues
as may be required by regulatory/supervisory bodies.
i) Deliberate refusal to disclose all information and
transactions during investigations, supervision and
examinations by regulatory/supervisory bodies
j) Non/inadequate disclosure of Directors, management
and related parties credit facilities to the appropriate
authorities.

2.4 Misuse of Information

a) Misuse, manipulation or non-disclosure of material
information on products/services and operations
provided to the Regulatory and Supervisory

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 Authorities in order to derive some benefits or avoid
liability.
b) Deliberate rendition of inaccurate or incomplete
returns to the Regulatory and Supervisory Authorities
with intent to mislead.
c) Running down competitors (de-marketing) through
deliberate misinformation, dissemination of negative
information in order to sell products and services or
derive benefits.
d) Misuse of various financial products/services and
their derivatives.
e) Misuse of confidential information obtained in the
course of the member’s business/employment.
(Liability clauses should be included in legible forms
to enable customers to become aware of them).
f) Use of proprietary or intellectual property of
competitors without prior written consent or
permission.
g) Misuse of marketing staff (ladies) as bait to woe
customers.

2.5 Insider Abuse

a. Improper granting of credit facilities to Directors,

Management, and other employees and political

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 interests. (Improper means failure to obtain relevant
approval or adequate collaterals, non-perfection of
securities or failure to disclose interest).
b. Conversion of the employer’s resources to purposes
other than for the business interests of the employer.
c. Granting of unsecured credit facilities to Directors and
other employees of the bank/Discount House in
contravention of the provisions of Banks and Other
Financial Institutions Act (BOFIA) 1991 (as amended)
d. Granting of interest waivers on non-performing insider
credits without CBN’s prior approval as required by
BOFIA.
e. Diversion of banks and Discount Houses employers’
assets and earnings e.g. through the use of
subsidiaries, “secret accounts” or any other channel
thereby denying the banks/Discount Houses of their
legitimate assets and earnings.
f. Failure to keep to the terms of agreement in order to
take undue advantage of the unsuspecting customer
and third party.
g. Taking advantage of weaknesses/loopholes inherent
in transactions known to him for selfish purposes.
h. Granting of Credit facilities above his approval limit.
i. Overriding of internal control systems and procedures
for undue/personal advantage
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j. Deliberate violation of laws, statutes and regulations.
k. Issuance of cheques against Dishonoured Cheques
(Offences) Act.
l. Engaging in money laundering activities or alerting
customers /suspected launderers of impending
investigation, etc.

2.6 Offer and Acceptance of Gratification

a) Offering gratifications to Regulators and Supervisors

as an inducement to influence them in the conduct of
their assignments
b) Offering gratifications to Inspectors/Compliance
officers/Controllers, Auditors (Internal and External),
c) Offering gratifications to government officials and law
enforcement agencies. e.g. Nigeria Police, EFCC,
NDLEA, ICPC,FIRS, etc
d) Applying double standards with the intention to
induce offer of gratifications.
e) Imposing unfair penalties e.g. by the Bank
Inspectors/Compliance Officer and Internal Auditors
with the intention to induce offer of gratifications.
f) Offering/acceptance of gratification to/from
customers respectively, and potential customers to do
business or to earn undeserved favour.

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g) Aiding a customer to evade legitimate charges, e.g.
Tariffs, Taxes, Fees, Bank Charges and Commissions,
etc, for whatever purpose/reason.

2.7 Non-conformity
a) Non-conformity with the Central Bank of Nigeria
Prudential Guidelines, Statements of Accounting
Standards (SAS), International Financial Reporting
Standards (IFRS) and any other Standards and/or
guidelines prescribed by law or regulation in the
preparation of financial statements, resulting in the
provision of inaccurate, incomplete or false
information.
b) Preparation of multiple financial statements in order
to mislead the regulatory authorities and other
stakeholders.
c) Neglecting to recognize inherent risks in the portfolio
of contingent liabilities in financial statements.
d) Failure to give reference about an employee to another
employer.
e) Failure to settle financial obligations owed to previous
employer in line with conditions of service and/or as
may be agreed by the parties (employer/employee).

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2.8 Aiding and Abetting
a) Aiding and abetting new staff not to meet financial
obligations to previous employer(s).
b) Aiding and abetting the confirmation of new staff
without obtaining satisfactory references, especially
from previous employer and/or other institutions.
c) Aiding and abetting the extension of probation period
for confirmation of employment of a new staff beyond
six (6) months or any applicable time frame where
initial unsatisfactory reference had been obtained in
the first instance.
d) Aiding and abetting deliberate use of female staff for
unwholesome conduct/practice, especially in order to
lure a high networth customer from another bank.
e) Turning a blind eye to management, staff, customers
and other stakeholders engaged in suspicious
activities.
f) Aiding and abetting customers to circumvent
statutory, regulatory and supervisory provisions/
guidelines.
g) Aiding and abetting non-prosecution of employees
who engage in fraudulent and other criminal
activities.

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h) Refusing to co-operate with law enforcement agents in
the course of their investigation and prosecution of
suspected employees.

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 SECTION 3
BANKS AND THEIR CUSTOMERS

3.1 Governing Principles

Banks shall:

a) Set out the standards of good banking practice which

they shall follow in their dealings with their customers
and other consumers.
b) Conduct their business in the best ethical and
professional manner consistent with global best
practice.
c) Provide and enforce guidelines to make their staff act
ethically and professionally in all their dealings with
customers, other banks and stakeholders.
d) Assist customers to understand the operations, rules,
guidelines and regulations as well as products and
services and known risks relating to banking
operations and services.
e) Inform their customers of the products and services
which are best suited to their needs based on their
personal/individual financial situation(s).
f) Maintain and sustain public trust and confidence in
the banking system to ensure its integrity and
security.

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g) Operate within the statutory, legal and regulatory
framework, in word and deed.
h) Always place their customers’ interests above all
others.
i) Always meet their commitments which shall not be
lightly given, and should never be broken.
j) Repay depositors their deposits at maturity, deliver on
their trading contracts and lend on agreed terms and
conditions.
k) Deal only with known parties, i.e. take all reasonable
steps to establish that all parties they deal with are
genuine.
l) Not pay brokerage/commission to their employees
m) Disclose, from the beginning, contracts or business
which brokerages/commissions are payable and also
disclose such payments.
n) Adopt only ethical and professional practices in their
recruitment and deployment of personnel.
o) Have in place pre-employment background screening
process as an effective human risk management tool
to provide a degree of certainty that potential
employees have desirable background, requisite
knowledge and skill for the job.

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p) Provide healthy competition without undermining
other Banks’/Discount Houses stability in the course
of marketing products and services.
q) Bring to the attention of their customers various
communication channels, e.g. SMS, e-mails and
letters through which all forms of information can be
conveyed to them.
r) Inform the customers of all financial transactions in
their accounts.
s) Display high degree of fairness and transparency in
the conduct of their business and relationship with
other parties.
t) Keep proper books of accounts and records.
u) Strictly observe the mandates of their customers.
v) Put in place a whistle blowing policy and framework.
w) Sanction employees appropriately for violation of this
Code of Conduct
x) Avoid double standards in the application of sanctions
to employees for the violation of this Code of Conduct

3.2 Opening an Account

Banks shall:
a) As prescribed by the Central Bank of Nigeria, (CBN)
under Know Your Customer and his Business (KYCB)

27
 principles, satisfy themselves about the identity,
address and business of the person seeking to open
and operate a bank account with them in order to
assist in protecting their customers, members of the
public, themselves and the banking system against
frauds and other misuse of the banking system.
b) Provide to prospective customers at the time of
opening an account the details of identification
requirements and other documents necessary to
ensure that minimum KYCB requirements are in
place.
c) Educate customers on the proper handling and
security of cheque books and other security/electronic
instruments, e.g. ATM, Mobile phone/internet
banking and other payment channels.
d) Respond to status enquiries from other banks and
financial institutions within two (2) weeks of receipt of
such requests.
e) Put in place the KYCB process and ensure compliance
in line with the regulatory requirements.

3.3 Terms and Conditions to Customers

All terms and conditions shall be in line with the subsisting

laws and regulations.

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Banks shall:
a) Provide to customers clearly written and legally
enforceable terms and conditions, expressed in simple
language, on the various types of financial products
and services offered by them.
b) Ensure that adequate notice is given to customers
about any change in the terms and conditions relating
to financial products and services offered. (For
changes resulting from administrative or statutory or
regulatory actions of the Authorities, for examples
notices as contained in the Monetary Policy Circulars
(or any other circulars from the Regulatory
Authorities), the communication of such notices by a
bank to the customer should be considered adequate).
c) Send comprehensive statements of accounts to
customers, at regular intervals or as may be agreed by
the parties (except where expressly waived by the
customer), in order to enable customers to manage
their accounts effectively. Customers should, in
addition, be availed the balances in their accounts on
request.

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3.4 Charges and Interest Payable by Customers/
Consumers

Banks shall:
a) Disclose to Customers/Consumers in sufficient
details:
i. The basis and amount of charges incidental to
the operations of their accounts/transactions.
ii. Such charges shall be as contained in the Guide
to Bank Charges or any other Guide/Tariff
published by the Bankers’ Committee, from time
to time.
iii. Changes in interest rates or other rates/charges
when accounts are opened, booking of new
transactions or changes in earlier agreed terms,
and upon request by customers/consumers.
iv. Information about changes in the Guidelines and
shall make them available to the customers/
consumers.
b) Provide information on charges for services not
covered by the Guide to Bank Charges (provided such
services are recognized by the Bankers’ Committee at
the point of rendering the services or upon request.
c) Inform their customers of the interest rates that they
apply to the debit balances on their accounts, the

30
 basis on which they are calculated and the timing of
the debit.
d) Inform their customers of the basis on which interest
rates and other charges may be varied.
e) Give reasonable notice to their customers on changes
in rates and charges and obtain acknowledgment.

3.5 Interest Payable to Customers

Banks shall:

a) Make information freely available and accessible to

customers by one or more effective means, about the
rates on all interest bearing accounts which they offer,
for example by:
i. Verbal and/or written notices e.g. letters and
circulars
ii. Brochures/Leaflets at Head, Regional/Zonal,
Area and Branch Offices
iii. Press advertisements
iv. Telephone/fax services; and
v. Internet, text and e-mail services and/or other
acceptable means of effective communication.
b) Inform customers about the interest rates applicable
to/payable on their deposit, fixed, savings and other
accounts, the basis on which the interest is calculated
and when it will be credited to their accounts.
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c) Inform their customers of the basis on which they
(banks) may vary the deposits/savings interest rates.
d) Publicize changes in interest rates, “with immediate
effect” by notices in their branches, or in the press, or
on statements of account or letters addressed to their
customers or other agreed means of communication or
a combination of any or all of these methods.
e) Notify their borrowing customers in writing about
changes in interest rates and obtain
acknowledgement.

3.6 Handling Customers’ Complaints

Banks shall:
a) Treat customers/consumers fairly/and equitably.
b) Each, have internal policies, structures, guidelines
and procedures for handling customers’/consumers’
complaints expeditiously.
c) Set up Complaint Desks in all their branches, other
operational offices and Head Office and inform their
customers that they have internal policies, structures,
guidelines and procedures for handling complaints.
d) Make available to their customers details on how
complaints can be made and what further steps they
can take if they believe that a complaint was not

32
 handled satisfactorily either at the point of first report
or at any other level within the bank (e.g.
Area/Regional/Zonal and Head Offices).
e) Ensure that all their employees who deal with
customers understand their internal policies,
structures, guidelines and procedures for handling
complaints and are capable of assisting customers
with adequate, correct and timely information.
f) Have channels, in addition to placing framed
messages, indicating customer care centres/customer
service desk, complaint desks, postal addresses,
dedicated Short Messaging Services (SMS) lines,
telephone lines, e-mail addresses, and other means,
for lodgment of complaints by customers/consumers,
in their operational locations especially branches.
g) Ensure that all customers’ written complaints are
acknowledged in writing or through emails within
reasonable days of receipt.
h) Ensure that all customers’ complaints are resolved
within reasonable time frame of receipt of a written
complaint.

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3.7 Confidentiality of Customers’ Information
Banks shall:
a) Observe strict duty of confidentiality about
their customers’ and former customers’ affairs
and shall not disclose details of customers’
accounts/transactions or their names and
addresses to any third party, including other
companies in the same group, other than in the
four exceptional cases as stated in section 1.2
above.
b) Insist on Directors, Management and staff
signing a “Declaration of Secrecy” to ensure the
confidentiality of customers’ information.

3.8 Status Enquiries (Bankers’ References)

Banks shall, on request:
Provide Bankers’ References or Bankers’ Opinion in reply to
Status Enquiries made on their customers in line with
banking practice and regulation.

3.9 Marketing Services

Banks shall:
a) Not pass customers’ names and addresses to other
companies in the same group for marketing purposes,
except where a customer has given his express written
34
 consent. For this purpose, written consent by a
customer shall not be made a condition for provision
of basic banking services by banks.
b) Act responsibly, transparently and prudently in
marketing and delivery of financial services.
c) In particular, ensure that all advertisements and
promotional literature are fair and professional,
contain no misleading information and comply with all
relevant legislations and regulations whether relating
to their own bank or their competitor banks.

3.10 Foreign Exchange Services and Cross-Border

Payment

Banks shall:

a) Provide customers with details of the Exchange Rates

and the charges which will apply to Foreign Exchange
transactions.
b) Provide customers wishing to effect Cross-Border
Payments with details of the services they offer. In
doing so, they shall provide, as a minimum:
i) Basic description of the services available and
the manner in which they can be used.
ii) Information as to when money sent abroad, on
customers’ instructions, will usually reach its
destination or, when an exact date cannot be
35
 given, the latest date by which the money might
be expected to reach the destination; and
iii) The details of any commission or charges
payable by customers to their bank, including a
warning where agents’ charges may also be
incurred.

3.11 Guarantees and Other Types of Third Party

Securities

Banks shall:

a) Inform their customers that;

i. By giving guarantee or third party security, the
individual might become liable instead of, or as
well as, that other person being guaranteed.
ii. That he or she should seek independent legal
advice before entering into any guarantee or
third party security.
b) Ensure that Guarantees and other third party
securities’ documentations shall contain clear and
prominent notice of the terms and conditions.

3.12 Inter-bank Transaction

Banks shall:
a) At all times and as expeditiously as possible, seek
through recognized channels adequate information
36
 about the credit-worthiness of other banks before
engaging in inter-bank transactions with them.
b) Accord priority to inter-bank obligations.
c) Collaborate with other operators, regulators and the
Institute to sanitize the banking industry.

37
 SECTION 4:

INFRINGEMENTS AND SANCTIONS

4.1 Infringements:

A member shall be deemed to have committed an

infringement under this Code if, he:

a) For the purpose of procuring membership registration

of any name, qualification or other matters:
i) makes a statement which he knows, or is
proved, to be false in a material particular; or
ii) without exercising reasonable caution,
recklessly makes a statement which is false in a
material particular.
b) Is declared bankrupt.
c) Is committed to imprisonment as a result of criminal
offence.
d) Is sanctioned by another recognized professional body
for unethical and unprofessional conduct/activities.
e) Asks for, consents or agrees to receive any
gratification or bribe in money or in kind, personally
or through his relations, associates or other third
parties, from customers or prospective customers or

38
 consultants or contractors of his employer and
coworker:
i) For procuring or attempting to procure an
advance, loan or credit facility, or contract.
ii) For the purchase or discount of any draft, note,
cheque, bill of exchange or other obligations by
the employer.
iii) For granting loan, advance or credit facility to any
person inconsistent with the policies, rules and
guidelines of his employer and the subsisting
laws and regulations in the industry.
f) As a Director, Manager, Officer, Secretary, or a similar
office holder of the body corporate purporting to act in
any such capacity, connives, has knowledge of, or
negligence is attributable on his part in a criminal
offence.
g) As an employee/member, he is alleged of any
unethical and unprofessional conduct/practice and
referred to the Disciplinary Mechanism of CIBN.
h) Fails to circulate the names of employees/members
involved in fraud and forgeries as required by Central
Bank of Nigeria, Nigeria Deposit Insurance
Corporation and the Institute.
i) Hires a person that has been found guilty (dismissed
or terminated) of fraud and/or other criminal,
39
 unethical, and unprofessional activities in any bank or
any other organization.

4.2 Enforcement of the Code of Conduct

It is the duty of all members to assist and co-operate
with the Institute in the course of enforcing this Code.

4.3 Framework for Handling Reported Cases Involving

Individual Members

4.3.1 Cases Involving Individuals

All cases relating to individual members brought

before the Institute in connection with this Code shall
be handled by The Chartered Institute of Bankers of
Nigeria Investigating Panel and where necessary, The
Chartered Institute of Bankers of Nigeria Disciplinary
Tribunal.

4.3.2 Procedure for Handling Individual Member Cases

i) All complaints/petitions involving members
should be duly signed and addressed to the
Registrar/Chief Executive of the Institute in
triplicate copies.
ii) The complaint/petition shall be acknowledged
in writing within seven (7) days of receipt by the
Institute.
40
iii) The letter of acknowledgement of any case
brought before the Institute shall include a
clause prohibiting all parties, pending the
determination of the case, from:
a. Commenting on the matter in the mass
media, and;
b. Taking the case to the law court or any
other dispute resolution organ
iv) A copy of the complaint/petition shall be
forwarded to the defendant and/or other
parties mentioned in the case for his/their
response(s) (in triplicate copies).
v) The Institute shall collate the petition and
submission(s) of the defendant/other parties
and refer them to the CIBN Investigating Panel.
vi) The CIBN Investigating Panel shall investigate
the case and decide whether or not it should be
referred to The CIBN Disciplinary Tribunal.

In carrying out its investigations, The Panel may:

a. Seek the assistance of any person(s) including:
– Banking Supervision Department and OFID of
CBN;
– Bank Examination Department and SIID of
NDIC;
41
 – Committee of Chief Inspectors of Banks in
Nigeria;
– Financial Market Dealers Association of
Nigeria;
– Nigerian Discounts Market Association;
– National Association of Micro-Finance Banks
of Nigeria;
– Mortgage Banking Association of Nigeria;
– Risk Managers Association of Nigeria;
– Human Capital Managers of Banks
Association;
– Committee of Chief Security Officers of Banks;

– Committee of Chief Compliance Officers of

Banks in Nigeria (CCCOBIN);
– Independent Consultants;
b. Summon parties and witnesses.

The CIBN Investigating Panel shall:

a) If the case has merit, refer it to the CIBN Disciplinary

Tribunal through the Registrar/Chief Executive and
serve as the Prosecutor.
b) b. If the case has no merit, notify the Registrar/Chief
Executive of its findings and decisions.

42
 c) The Registrar/Chief Executive shall inform the parties
of the findings and decisions of the CIBN Investigating
Panel.

The CIBN Disciplinary Tribunal shall:

a) Consider and determine the case referred to it by The

CIBN Investigating Panel.
b) Report to the Governing Council its decisions for
confirmation.
c) Convey its direction to the person(s)/parties
concerned.
d) In the performance of its functions, The CIBN
Disciplinary Tribunal may refer a case back to the
CIBN Investigating Panel or summon the parties and
witnesses.

Resolutions of cases either by the CIBN Investigating Panel or

the CIBN Disciplinary Tribunal shall be deemed to be binding
on all parties concerned.

At all stages – whether at the CIBN Investigating Panel or

The CIBN Disciplinary Tribunal, parties may be allowed to
appear with their Counsels. Counsels may however, not be
allowed to represent a party without that party being present
at the hearing.

43
4.4 FRAMEWORK FOR HANDLING REPORTED CASES
INVOLVING CORPORATE MEMBERS

4.4.1 Cases Involving Corporate Members

All cases relating to Corporate Members in connection
with this Code shall be handled by the Bankers’
Committee Investigating Panel (BCIP) and Bankers’
Committee Sub-Committee on Ethics and
Professionalism (BCSEP).

4.4.2 Procedure for Handling Cases Involving Corporate

Members

The BCSEP shall apply the following procedures for

handling cases brought before it:
a) All complaints/reports shall be submitted to
the Secretariat of the Sub-Committee at CIBN.
b) Such complaints are to be acknowledged in
writing within seven (7) days of receipt. The
letter of acknowledgement of any case brought
before the Sub-committee shall include a clause
prohibiting all parties, pending the
determination of the case, from:
i) Commenting on the matter in the mass
media, and

44
 ii) Taking the case to the law court or any
other dispute resolution organ
c) The Secretariat shall request for submission
from the respondents or other parties
mentioned in a petition before it.
d) The Secretariat shall collate the submissions
from the complainant and respondent.
e) The Secretariat shall inform the Chairman of
the Sub-Committee on receipt of such cases.
f) All cases (with the responses and other
documentations received) are to be referred to
the BCIP.
g) The BCIP is free to choose any or a
combination of the following organs to assist in
conducting investigations:
• CIBN Investigating Panel;
• Banking Supervision Department and Other
Financial Institutions Department (OFID) of
CBN;
• Bank Examination Department, and Special
Insured Institutions Department (SIID) of
NDIC;
• Committee of Chief Inspectors of Banks in
Nigeria;

45
 • Financial Market Dealers Association of
Nigeria;
• Nigerian Discounts Market Association;
• National Association of Micro-Finance
Banks of Nigeria;
• Mortgage Banking Association of Nigeria;
• Risk Managers Association of Nigeria;
• Human Capital Managers of Banks
Association;
• Committee of Chief Security Officers of
Banks;
• Committee of Chief Compliance Officers of
Banks in Nigeria (CCCOBIN);
• The BCIP shall make its recommendations
to BCSEP for consideration.
h) The BCSEP shall report its decisions to the
Bankers’ Committee for confirmation.
i) All cases referred to the BCSEP should be
disposed off without delay but not later than six
(6) months from date of receipt of the petition.
j) In the event that any case may exceed six (6)
months the parties should be informed
accordingly.

46
4.4.3 Sanctions For Violating This Code By Individual
Members.

i) Where:-
a) A person is adjudged by The CIBN Disciplinary
Tribunal to be guilty of unprofessional conduct in any
professional respect: or
b) A person is convicted by any court or tribunal in
Nigeria or elsewhere having power to award
imprisonment for an offence (whether or not
punishable with imprisonment) which in the opinion
of The CIBN Disciplinary Tribunal is incompatible with
the conduct required of a member of the banking
profession; or,
c) The CIBN Disciplinary Tribunal is satisfied that the
name of any person has been fraudulently registered,
The CIBN Disciplinary Tribunal shall, if it deems fit,
convey a direction to the person concerned
reprimanding that person or ordering the
Registrar/Chief Executive to strike his name off the
relevant part of the membership Register.
d) A person who commits an offence and is found guilty
by the decision of The CIBN Disciplinary Tribunal
shall be liable to the maximum sanction of having his
name struck out from the Register of members.

47
ii) The CIBN Disciplinary Tribunal may, if it deems fit,
defer or further defer its decision as to the giving of a
direction until its subsequent meeting:
a) No decision shall be deferred for a period
exceeding three (3) months from the conclusion
of proceedings in the case; and
b) No person shall be a member of The CIBN
Disciplinary Tribunal for the purposes of
reaching a decision which has been deferred or
further deferred, unless he was present as a
member of The CIBN Disciplinary Tribunal
when the decision was deferred. For this
purpose, a person shall not be treated as guilty
as therein mentioned unless the guilt stands at
a time when no appeal or further appeal is
pending or may (without extension of time) be
brought in connection with the direction.

iii) When The CIBN Disciplinary Tribunal gives a

direction, it shall cause notice of the direction to be
served on the person to whom it relates.

iv) The person to whom a direction relates may, at any

time within twenty-eight (28) days from the date of
service on him of the notice of the direction, appeal
48
 against the direction, to the Federal High Court and
where necessary to the Court of Appeal and The CIBN
Disciplinary Tribunal shall appear as respondent to
the appeal and, for the purpose of enabling directions
to be given as to the costs of the appeal and of
proceedings before the Federal High Court or Court of
Appeal, the Disciplinary Tribunal shall be deemed to
be a party thereto, whether or not it appears at the
hearing of the appeal.

v) A direction of The CIBN Disciplinary Tribunal

shall take effect if:

a) No appeal is brought against the direction,

within the time limit for such an appeal, or on
the expiration of that time.
b) Such an appeal is brought and is not
withdrawn or struck out for want of diligent
prosecution, upon the withdrawal or striking
out of the appeal.
c) Such an appeal is brought and is withdrawn or
struck out as afore-said, if and when the appeal
is dismissed, and shall not take effect except in
accordance with the foregoing provisions of this
Code.

49
vi) A person whose name is struck off the register in
pursuance of a direction of The CIBN Disciplinary
Tribunal under this section shall not be entitled to be
registered again, except, in pursuance of a direction in
that behalf and a direction for the striking off of a
person’s name from the register prohibits him from
making an application for membership or restoration
of his membership until after the period specified by
the direction that his name should remain struck off,
and if he makes an application during the currency of
the prohibition such application shall be invalid.
However, where the case in question is on fraud and
other criminal offences, the person’s name shall not
be restored at all except where such a person is
discharged and acquitted from all charges of fraud
and criminal offences by a court of competent
jurisdiction.

vii) Any member who institutes a legal action against

another member on matter(s) relating to the Institute
without the express permission in writing of the
Governing Council shall be liable to the following
penalties:

50
 a) Withdrawal of Membership;
b) Reporting to the employer for bringing the
name of the Institute into disrepute.

4.4.4 Sanctions for Violating This Code By Corporate

Members
In the application of sanctions on all cases involving
corporate members under this Code, the fundamental
principles of restoration, retribution, deterrent and
equity shall be given priority.

In all cases of sanctions, specific time frame shall be

stated for compliance.

Where a corporate member fails to comply within a

stipulated time-frame with the decision of the BCSEP,
the CBN shall be notified to enforce compliance.
i) Where offences contradict existing statutory
provisions and regulatory guidelines, the
prescribed sanctions would apply.
ii) For offences with no precedent, the BCSEP
would use its best judgment based on the
principles enunciated above. In such cases, the
BCSEP will recommend specific sanctions to
the Bankers’ Committee.
51
4.4.5 Appeal by Corporate Members
A Corporate Member has the right of appeal.
Such an appeal shall be entertained only if the applicant had
given notice and complied with the decision of BCSEP within
one (1) month of the decision.

The appeal shall be heard by an Independent Appeal

Committee (IPC) made up of four (4) former practitioners and
three (3) permanent members of the BCSEP.

The IPC will be chaired by any of the following:

i) Former Governor or Deputy Governor of CBN,
ii) Former Managing Director or Executive Director of
NDIC
iii) Former Managing Director of a bank

52
 SECTION 5:

ESTABLISHMENT OF THE CIBN INVESTIGATING PANEL

AND DISCIPLINARY TRIBUNAL (EXTRACT FROM THE
CIBN ACT)

There shall be a body to be known as The Chartered Institute

of Bankers of Nigeria Investigating Panel (hereafter in this
Act referred to as “The Investigating Panel)” which shall be
charged with the duty of:
a) Conducting a preliminary investigation into any case
where it is alleged that a member has violated the
provisions of the Institute’s Code of Conduct or shall
for any other reason be the subject of proceedings
before The CIBN Disciplinary Tribunal; and
b) Deciding whether or not the case should be referred to
the CIBN Disciplinary Tribunal.

5.1 Appointment of the Investigating Panel

The CIBN Investigating Panel shall be appointed by
the Governing Council and shall:
Consist of five (5) members of the Institute, two of
which shall be members of the Governing Council
with one as the Chairman of the Panel and three other
members who are not members of the Governing
Council.
53
5.1.1 The tenure of any member of The CIBN Investigating
Panel shall be two years renewable for a further period
of two years.
5.1.2 The CIBN Investigating Panel shall act independently
in the receiving and investigation of allegations under
paragraph (a) of Sub-section 1 of this section and
shall have power to receive complaints directly from
any individual or organization.

5.2 Establishment of the CIBN Disciplinary Tribunal

i) There shall be a Tribunal to be known as The
Chartered Institute of Bankers of Nigeria, CIBN,
Disciplinary Tribunal (hereafter in this Act referred to
as “The CIBN Disciplinary Tribunal”) which shall be
charged with the duty of considering and determining
any case referred to it by The CIBN Investigating Panel
and any other case of which The CIBN Disciplinary
Tribunal has cognizance of.

ii) The CIBN Disciplinary Tribunal shall be appointed by

the Governing Council and shall consist of the 2nd Vice
President of the Institute as the Chairman, three other
members of the Governing Council, and three
members of the Institute who are not members of the
Governing Council.
54
iii) The tenure of any member of The CIBN Disciplinary
Tribunal shall be two years renewable for a further
period of two years.

5.3 Composition of Bankers’ Committee Investigating

Panel (BCIP)

The BCIP shall comprise the following:

• Permanent members – CBN, NDIC, CIBN,
• Rotational Members – seven (7) representatives of
Banks who are members of the BCSEP.

5.4 Composition of Bankers’ Committee Sub-

Committee on Ethics & Professionalism (BCSEP)

The BCSEP shall comprise the following:

• Permanent Members - CBN, NDIC, CIBN,
• Rotational Members – seven (7) Managing Directors of
Banks.
Signed: 9th Day of April 2013

…………………………………. ……………………………
President/Chairman of Governor, CBN/Chairman,
Council, CIBN Bankers’ Committee

55