THE NIGERIAN SUSTAINABLE BANKING PRINCIPLES (NSBP) A FIVE YEAR REVIEW
THE NIGERIAN SUSTAINABLE BANKING PRINCIPLES (NSBP) A FIVE YEAR REVIEW
Acknowledgement We are grateful to all the participating Banks, Development Finance Institutions, and Microfinance banks, in the survey that led to this study. We are particularly thankful to the following professionals who provided more elucidation in an indepth interview:
Ÿ Dr. A'isha Usman Mahmood, Special Adviser to the CBN Governor on 'Sustainable Banking' Ÿ Prof. Ken Amaeshi, Political Economist and teacher of International Business at the University of Edinburgh business school, UK Ÿ Damilola Sobo Smith, Environmental and Social Risk Management Project Coordinator, International Finance Corporation (IFC)
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Contents SUMMARY OF OUTCOMES ABOUT THE STUDY WHY SUSTAINABLE BANKING? THE NSBP SURVEY FINDINGS CONCLUSION RECOMMENDATIONS APPENDIX REFERENCES
Summary of Outcomes
F
ive years ago (July 22, 2012), the Central Bank of Nigeria (CBN) identified the need for an international yet country specific standard for financial performance and in line with global standards, developed the Nigerian Sustainable Banking Principles which was approved by the Bankers Committee of Nigeria. The principles – a set of Nine (9) policies, basically covering Environmental and Social performance issues was designed based on leading international sustainable finance standards and established industry best practice and also in line with the Nigerian context and specific development needs. (NSBP Guidance Note, Final Version). Since inception, the Apex bank has held the belief that the principles would enhance the success of financial institutions whilst also ensuring that they remain environmentally and socially responsible. Financial experts also envisioned that the principles would 'clean up' banks, especially after the series of banking crises experienced in the country. Besides, many believe that the adoption of the principles has created a new market for sustainable services for both international and foreign players while others are certain that the implementation of the principles has so far initiated commitment to sustainability, which would subsequently translate to the sustainability of the Nigerian banking industry. It therefore becomes imperative to investigate the current state of the industry after the initiation of the principles; from the launch and adoption, to the current state of implementation and progress, to ascertain if it meets the high expectations as well as its suitability for ensuring the country's financial sector is sustainable.
6 | (NSBP) A FIVE YEAR REVIEW
Hence, ThistlePraxis, a Strategy and Assessment Consulting Firm, in this study provides an in-depth review on the first five years of the NSBP.
Key Outcomes
Most institutions have dedicated officers who coordinate the implementation of the
94%
88%
26
of the respondents are aware of the NSBP; only 6% are unaware;
of respondent banks have adopted the NSBP;
All twenty six (26) deposit money banks who are signatories have adopted and are at different stages of implementation;
NSBP
PRINCIPLE
PRINCIPLE
(4) and six (6) (2) and one (1)
86% of respondents are satised with the role of the CBN in the adoption process;
Women Economic Empowerment and E&S Governance, respectively, appear to have recorded the most success in the implementation for the respondent institutions that have adopted the principles.
86%
50%
of NSBP signatory banks have submitted at least one report to the CBN after their dates of adoption;
of respondent banks considered the compliance and reporting process straightforward and the other 50% consider it complicated;
80% of respondent banks have realised some form of benets from their implementation of the NSBP and investments in it;
Environmental and Social Footprint and Environmental and Social Risk Management, respectively, have proven most challenging to implement for respondent institutions;
69% Respondents of the respondents attributed are condent in the the challenge with credibility of the reporting to NSBP as a driver difculty with of sustainable implementation; banking in Nigeria, if properly implemented;
33% of respondents are convinced that the current economic situation of the country has affected/affects their implementation of the NSBP, majorly in the form of reduction in budgetary allocation;
Lack of infrastructure and limited resources are the major challenges expressed by the institutions and expert bodies, as facing proper implementation;
81% of respondents reported that the NSBP is relevant for their type of institution (commercial, micronance or development nance);
Development Finance Institutions seem to be the most bothered by the relevance of the principles to their structures and operations;
67% of respondent banks called for a review of the principles whilst the CBN Sustainable Banking Ofce does not think they are yet due for a review;
Reporting format, monitoring and implementation are top 3 aspects respondents requested improvements on.
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About this Report
F
inancial institutions play strategic roles in the economic development of a nation as a catalyst for economic progress and poverty alleviation that ensure the general wellbeing of the economy and the people. Since the inception of the banking sector in Nigeria in 1890, there have been several cases of devastating distresses that have left the sector unstable until the 2000s. The consecutive seasons of illiquidity, insolvency, and closure of banks in the 1990s dipped the hitherto growing saving culture of Nigerians, led to job and business loses and trimmed foreign investments. The most tumultuous
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bank crisis in 2009 thereafter left twenty four (24) banks on the brink of collapse, initiated a bail out of eight by the Central Bank of Nigeria (CBN) and led to several bank mergers. Yet, with every bank distress comes a negative ripple effect on every sector of the economy. In order to manage the risk of continuous distress in the banking sector, the CBN in 2012 integrated sustainable business practices into the sector with the prioritisation of Sustainable Banking and Environmental & Social Risk Management. The Nigerian Sustainable Banking Principles (NSBP) came into force on July 22, 2012 after the Bankers' Committee
approved its adoption for Banks, Discount Houses, and Development Finance Institutions in Nigeria. Thirty four (34) financial institutions signed and committed to implement the principles. The business of risk (management) is indeed risky. Due to the nature of environmental & social risks, no management system is fullproof and the existence of standards and thorough due diligence may not mitigate unprecedented risks in a fast changing world as we currently experience. However, the process where these undesired outcomes are envisaged and prepared for makes environmental & social risk management an imperative for all organisations – not only financial institutions. The statistics around climatic change makes the future somewhat bleak and highly uncertain. How the business environment accommodates and withstands these changes with innovative strategies remains the primary focus of the NSBP. The nine (9) principles require the signatories to formally integrate environmental and social risk management into investment and lending decisions, by introducing frameworks to identify, assess and mitigate such risks. They cover areas such as environmental and social risk management, governance, transparency and accountability, whilst supporting capacity building in the sector and promoting collaborative partnerships to accelerate progress. In addition, it is well thought-out so they cover the areas of women's empowerment and financial inclusion. Most importantly, the Principles include specific sector guidelines, customising risk assessment in the high-risk sectors of oil and gas, power and agriculture. When signing the principles, an organization 1
commits to a strict timeline of implementation, with clear expectations, deadlines and milestones to meet annually. The principles represent an impressive aim to drive change in a crucial sector of the country's economy. While the principles are consistent with international standards such as the Equator Principles, they are tailored to the Nigerian context and development imperative, which is critical to their successful implementation. Successful implementation of the principles will therefore have a significant impact on the sustainability of the Nigerian banking sector, the oil and gas, power and agriculture sectors, as well as pave the way for sustainability and responsible business practice in Nigeria. Fast forward to 2017, five years after the adoption of the principles, most of the initial signatories are still standing, with more institutions licensed. A number of the initial 34 financial institutions openly and constantly accede commitment to the principles whilst as the regulatory body, the CBN affirms responsibility in ensuring that the principles are complied with and adequate punitive measures are applied against defaulting signatories. The nudging question then is: if the NSBP has indeed moved beyond the buzz of the adoption to implementation, how sustainable has the financial sector become? 1
 with the exception of those that are merged or change status (NSBP) A FIVE YEAR REVIEW | 9
Objectives The primary aim of this study is to review the objectives of the NSBP vis à vis achievements within five years of its adoption and consequently, present feasible improvement strategies to certainly ensure the sustainability of the Nigerian financial sector. The study therefore: Ÿ Investigates and analyses the current state of the NSBP and its impact on Banks, Discount
Houses, and Development Finance Institutions; Ÿ Examines and proffers solutions to some of the niggling challenges facing financial
institutions in implementing the principles; Ÿ Suggests ways for better performance of the principles – providing a nudge towards
initiating a review of the NSBP, to ensure it fits into current realities; Ÿ Provides a resource and reference point on maximising the NSBP for Sustainable Banking in
Nigeria.
Methodology This study was developed based on the findings from a survey which was administered on professionals of Nigerian Banks, Discount Houses, and Development Finance Institutions, via an online platform. Twenty one (21) commercial banks, Five (5) Discount Houses, Six (6) Development Finance Institutions and Ten (10) Micro Finance Banks were invited to participate in the survey, within a period of three (3) months. Responses were received from Sixteen (16) institutions as distributed below:
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Institutions Micronanace Banks 19%
Development Finance 12%
Commercial Banks
Commercial Banks 69%
Development Finance
Micronanace Banks
The survey responses were supplemented by in-depth interviews with three professionals who provided more insight from the perspective of the governing body, industry expert, and the international finance body.
Scope This study is limited to Nigerian Commercial Banks, Micro Finance Banks, Discount Houses, and Development Finance Institutions only. Sustainable Banking is viewed in terms of global standards such as the International Finance Corporation, the Equator Principles; as well as its connotation to the Central Bank of Nigeria (CBN). The survey that led to this study was however not carried out for the purpose of monitoring compliance with the NSBP and is therefore not expected to be an indictment of any financial institution in Nigeria.
Limitation Although Twenty one (21) commercial banks, Five (5) Discount Houses, Six (6) Development Finance Institutions and Ten (10) Micro Finance Banks were invited to participate in the survey, only sixteen (16) participated. (NSBP) A FIVE YEAR REVIEW | 11
Why Sustainable Banking? The role of financial institutions as major players in achieving sustainable development can be traced to the foundation of the first banks in Italy in the 16th Century. These banks were founded on the premise of serving as intermediaries between those who could provide capital and those who needed capital to start or conduct business; these businesses grew to become the spine of the economy. In most markets today, the financial sector provides a significant portion of the total investment capital of industries, making it a powerful sector in achieving sustainable economic development. Sustainable banking is the incorporation of Environmental, Social and Governance (ESG) standards into banking operations; an approach that recognises the role of financial institutions in driving responsible investments and projects within an economy. The importance of sustainable banking also dates back to the middle ages when religious ethics in the environment and local communities served as checks and balances to the first modern banks. Banks could only loan money to borrowers who worked hard, acted responsibly and took some levels of risks. The concept of sustainable banking gained popularity beginning from the 1990s when bankers realised that poor environmental performance on the part of their clients extended a threat to their business. The hunger for achieving sustainable banking in the sector hence birthed major financial sector sustainability initiatives such as the United Nations Environmental Program Financial Initiative (UNEP-FI), Global Reporting 12 | (NSBP) A FIVE YEAR REVIEW
Initiative (GRI), Financial Services Sector Supplement, Equator Principles, International Finance Corporation Principles of Responsible Investment (IFC-PRI), which globally guide the sector. The Nigerian Sustainable Banking Principles (NSBP) were thus modelled after these global standards, for the local market. Financial Institutions implement sustainable banking in two ways: Ÿ Funding/providing financial products and
services only for projects that present no/minimal negative impacts on the environment and community; Ÿ Ensuring their banking structure, day to day operations and activities pose no negative impacts on the environment and communities of operation (in locations, human capital, risks, costs e.t.c.). Integrating Sustainable Banking into strategy and business practices amongst other benefits, empowers organisations to better manage risks, increases brand reputation, boosts investors' confidence, improves customer relations and creates new investment opportunities. It therefore plays a crucial role in achieving overall sustainable development in any economy.
The Nine (9) Nigerian Sustainable Banking Principles (NSBP)
1
OUR BUSINESS ACTIVITIES: ENVIRONMENTAL AND SOCIAL RISK MANAGEMENT
2
OUR BUSINESS OPERATIONS: ENVIRONMENTAL AND SOCIAL FOOTPRINT
3
HUMAN RIGHTS
4
WOMEN'S ECONOMIC EMPOWERMENT
5
FINANCIAL INCLUSION
6
E&S GOVERNANCE
7
CAPACITY BUILDING
8
COLLABORATIVE PARTNERSHIPS
9
REPORTING
PRINCIPLE 1:
WE WILL INTEGRATE ENVIRONMENTAL AND SOCIAL CONSIDERATIONS INTO DECISION-MAKING PROCESSES RELATING TO OUR BUSINESS ACTIVITIES TO AVOID, MINIMIZE OR OFFSET NEGATIVE IMPACTS.
Environmental and Social (E&S) risks include but not limited to air or water pollution, environmental damage, destruction of biodiversity and cultural heritage, threats to human health and safety, violations of labour rights or displacement of livelihoods.
Under this principle, signatories are not expected to provide financial products and services to clients with poor E&S performance or fund business activities that can have potential negative impact on the environment and local communities where their clients operate. Therefore, financial institutions are expected to incorporate into their decision making process, an approach that systematically identifies, assesses and manages E&S risks and potential impacts associated with clients' business activities. Nevertheless, when risks are inevitable, they should seek to engage with the client to minimize and offset identified risks and impacts.
PRINCIPLE 2: This tenet clearly commits signatories to ensure WE WILL AVOID, MINIMISE that their daily activities and operations must be OR OFFSET THE NEGATIVE devoid of causing negative E&S impacts. Financial institutions are therefore required to find effective IMPACTS OF OUR BUSINESS ways of avoiding, minimising, and offsetting the OPERATIONS ON THE negative impacts their business activities can cause ENVIRONMENT AND whilst also innovating new means to achieving LOCAL COMMUNITIES IN positive gains. Using energy efficient resources, active participation in reducing the threats of WHICH WE OPERATE AND climate change and Greenhouse Gas emissions, as WHERE POSSIBLE, well as safe management of wastes are some of the PROMOTE IMPACTS. steps expected of every signatory. Moreover, there is need for compliance with labour laws, alignment of community investment projects with national social and economic development goals as well as a close monitoring of their supply chain to ensure E&S commitments are respected across board.
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PRINCIPLE 3:
WE WILL RESPECT HUMAN RIGHTS IN OUR BUSINESS OPERATIONS AND BUSINESS ACTIVITIES
Human and labour rights are to be respected by signatories, in their business operations. They are also responsible for ensuring the compliance of their supply chain with these laws/rights. Therefore, they are expected to develop human/labour policies that synchronise with international standards.
PRINCIPLE 4: According to this principle, women economic empowerment refers to the ability of women to participate in, wholly contribute to and fully benefit from the Nigerian economy without prejudice and in a way that recognises the value of their contributions, respects their dignity and creates a fairer distribution of income. It is demanded of signatories to develop products and services targeted at women, create opportunities for women leadership and contribution at all levels and develop/be committed to growing women's economic empowerment policy.
PRINCIPLE 5:
WE WILL PROMOTE FINANCIAL INCLUSION, SEEKING TO PROVIDE FINANCIAL SERVICES TO INDIVIDUALS AND COMMUNITIES THAT TRADITIONALLY HAVE HAD LIMITED OR NO ACCESS TO THE FORMAL FINANCIAL SECTOR.
WE WILL PROMOTE WOMEN'S ECONOMIC EMPOWERMENT THROUGH A GENDER INCLUSIVE WORKPLACE CULTURE IN OUR BUSINESS OPERATIONS AND SEEK TO PROVIDE PRODUCTS AND SERVICES DESIGNED SPECIFICALLY FOR WOMEN THROUGH OUR BUSINESS ACTIVITIES.
This rural-friendly principle requires of financial institutions: products and services that cater for the disadvantaged and marginalised groups within the society. Under this principle, every bank is expected to be accessible and friendly to the physically challenged. This principle is particularly significant as it ensures that financial entities contribute to poverty reduction, economic participation for all, support for SMEs and financial literacy for all.
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Under this principle, a signatory should be able to provide a clearly-defined E&S governance and accountability structure. It should also ensure same is set up by its clients whilst ensuring and encouraging performance. Periodic E&S Audit is another effective strategy to ensuring E&S commitments are constantly respected. Furthermore, signatories are expected to make information on E&S available to the public especially as regards progress in implementing the principles.
PRINCIPLE 6:
WE WILL IMPLEMENT ROBUST AND TRANSPARENT E&S GOVERNANCE PRACTICES IN OUR RESPECTIVE INSTITUTIONS AND ASSESS THE E&S GOVERNANCE PRACTICES OF OUR CLIENTS.
PRINCIPLE 7:
WE WILL DEVELOP INDIVIDUAL INSTITUTIONAL AND SECTOR CAPACITY NECESSARY TO IDENTIFY, ASSESS AND MANAGE THE ENVIRONMENTAL AND SOCIAL RISKS AND OPPORTUNITIES ASSOCIATED WITH OUR BUSINESS OPERATIONS.
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According to this principle, signatories are obligated to provide opportunities for skills development and capacity building on E&S risk identification and performance to its staff, from the top level down the employee pyramid.
With this principle, an end should come to undue competition and distancing among financial institutions. The principle encourages institutions to partner in developing the Nigerian economy and working towards sustainable banking in the country. There should be capacity building within the sector, as well as networking and collaboration for community investment/social initiatives. All should also commit to international sectorial standards like the Global Reporting Initiatives (GRI), International Finance Corporation Performance Standards (IFC-PS) e.t.c.
WE WILL COLLABORATE ACROSS THE SECTOR AND LEVERAGE INTERNATIONAL PARTNERSHIPS TO ACCELERATE OUR COLLECTIVE PROGRESS AND MOVE THE SECTOR AS ONE, ENSURING OUR APPROACH IS CONSISTENT WITH INTERNATIONAL STANDARDS AND NIGERIAN DEVELOPMENT NEEDS. PRINCIPLE 8
WE WILL REGULARLY REVIEW AND REPORT ON OUR PROGRESS IN MEETING THESE PRINCIPLES AT THE INDIVIDUAL INSTITUTION AND SECTOR LEVEL. PRINCIPLE 9
Every signatory is expected to develop monitoring, measuring, and evaluating metrics for tracking progress and implementation of the NSBP which should form a basis for a collective tracking of sustainable banking in Nigeria. Through internal reporting mechanisms, institutions are able to track individual performance and also make external reporting. Every signatory is also required to produce external performance/progress reports at least annually to initiate a nation-wide review of the performance of the principles towards ensuring the sustainability of the sector.
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Survey Findings
Financial Institutions 2
The Central Bank of Nigeria supervises nine (9) categories of Financial Institutions:
CATEGORIES
NUMBER OF REGISTERED INSTITUTIONS
Bureaux-de-Change (BDCs)
2991
Commercial Banks
22
Development Finance Institutions (DFIs)
6
Discount Houses
5
Finance Companies (FCs)
64
Merchant Banks
5
Micro-Finance Banks (MFBs)
1023
Non-Interest Bank
1
Primary Mortgage Banks (PMBs)
35
The NSBP was adopted in 2012 exclusively by Banks, Discount Houses, and Development 4 Finance Institutions3 - a total of Thirty Four (34). Hence, for the purpose of this study, ThistlePraxis invited Twenty one (21) Commercial Banks, Five (5) Discount Houses, and Six (6) Development Finance Institutions, to participate in the survey that led to the findings documented herein. In addition, Ten (10) Micro Finance Banks were also requested to take part in the survey. A total of Sixteen (16) Responses were received. 69% of total survey responses were received from Commercial Banks, 19% from Microfinance Banks, and 12% from Development Finance Institutions. However, no responses were received from Discount Houses.
2
As reflected on the website of the CBN at the time of this study (August, 2017)
3
All Banks, Discount Houses, and Development Finance Institutions registered with CBN as at 2012
4
See list in Appendix (NSBP) A FIVE YEAR REVIEW | 19
Proles
Head of Sustainability 27%
Other 34%
Head of CSR 13% Head of Compliance 13%
Head of Sustainability
Sustainability Ofcer 13% Head of CSR
Sustainability Ofcer
Head of Compliance
Other
27% of survey participants are Heads of Sustainability of their financial institutions, 13% are Sustainability Officers, 13% are Heads of Corporate Social Responsibility (CSR) and 13% are Heads of Compliance. Other responses which form 34% of total responses were given by Environment and Social Risk Management Team Members, Environmental and Social Risk Analysts, Environmental and Social Risk Coordinators, Monitoring Officers, and CSR Coordinators.
PinPoints This result shows that most institutions have dedicated officers who coordinate the implementation of the NSBP. It is however not surprising that all these officers are either in the Sustainability, CSR, Compliance, or Environmental and Social Risk Management departments. This is because the thrust of the principles is to ensure that financial institutions remain environmentally and socially responsible. Moreover, the fact that there are dedicated experts in charge of implementation reflects that the institutions are in line with the E&S governance provision of the NSBP, according to the implementation approaches of Principles 1 and 6. (Box 1 below).
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Box 1: Excerpts from Principles 1 and 6 Articulation of E&S governance and approval authority measures: Effective implementation of a Bank's E&S policies and procedures requires a defined governance structure with clearly articulated roles and responsibilities, structure and staff to implement E&S policy commitments. Integrating E&S Risk Consideration, Implementation of Principle 1 (Page 10, NSBP Guidelines)
Establish E&S Governance Responsibility: A Bank must establish clear lines of responsibility, authority and accountability in its governing structure when developing its Sustainable Banking policies and procedure... Developing E&S Governance approach, Implementation of Principle 6 (Page 24, NSBP Guidelines)
Awareness of Principles Awareness of Principles 6%
Yes 94%
Yes
No
94% of the respondents are aware of the NSBP while only 6% (from Microfinance) are unaware of the principles. (NSBP) A FIVE YEAR REVIEW | 21
PinPoints This high percentage of awareness amongst the institutions is highly commendable as it reflects prospect for a successful NSBP dispensation. Most importantly, the awareness and implementation of the principles by some Microfinance Banks is noteworthy as Microfinance Banks are not members of the Bankers' Committee and thus not signatories to the NSBP. 'Micro finance banks are not members of the Bankers' Committee and thus not signatories to the NSBP. However, efforts are being made to bring them on board. Series of sensitisation programmes have been conducted for Micro finance Banks'. Dr. A'isha Usman Mahmood - Special Adviser to the CBN Governor on 'Sustainable Banking'
Adoption No Idea 6% No 6%
Yes 88%
Yes No No Idea Unsurprisingly, 88% of respondent banks have adopted the NSBP given that most of them are members of the bankers committee that adopted it in 2012. However, about 6% of the respondents indicated that it has not been adopted by their banks while another 6% could not affirm the status of their institutions. Expectedly, the 12% who have either not adopted or are 22 | (NSBP) A FIVE YEAR REVIEW
unsure of their signatory status are from Micro-Finance Banks. 'All the 26 Deposit Money Banks who are signatories to the NSBP have adopted the principles and are at various levels of implementation'. Dr. A'isha Usman Mahmood - Special Adviser to the CBN Governor on 'Sustainable Banking'
It is however surprising that only 50% of the respondent banks reported to have adopted the NSBP in 2012, when in fact, the Bankers Committee (where all banks belong) claimed its members adopted it in 2012. Nevertheless, this disparity could be as a result of post-2012 bank mergers/the establishment of new banks which were not in place in 2012. In addition, implementation, according to sources did not kick off in earnest until Q1, 2013. Other respondents (50%) reported to have adopted in 2013 (29%), 2014 (14%) and 2016 (7%).
Role of CBN
Very Satised
Simply Satised
Averagely Satised
Most respondents (86%) indicated satisfaction with the role of the CBN in the adoption of the principles. Satisfaction levels expressed however ranged from very satisfied (40), simply satisfied (25) to averagely satisfied (35). In addition, the CBN via its sustainable banking office has pledged to continue to encourage all financial institutions under its purview to adopt the NSBP.
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PinPoints Irrespective of the actual kick off date, it is commendable that majority of the respondent banks have adopted the NSBP and the CBN has been in support of the adoption process.
Implementation PinPoints Findings from both respondent banks and the CBN reveal that within the five years of the NSBP, Women Economic Empowerment (Principle 4) and E & S Governance (Principle 6) appear to have recorded the most success in implementation from the banks; in terms of alignment of initiatives and proper reporting. 'All the 26 Deposit Money Banks who are signatories to the NSBP have adopted the principles and are at various level of implementation. So far, all the banks have in place policies and procedures for the implementation of the NSBP. Banks have made considerable progress in the area of women economic empowerment, financial inclusion, E & S Governance and E & S reporting'. Dr. A'isha Usman Mahmood - Special Adviser to the CBN Governor on 'Sustainable Banking'
Challenges with the Principles Financial Institutions have continued to express the challenges they face with implementing the principles. According to our survey, Environmental and Social Footprint (Principle 2) has proven most challenging to the banks to implement (30%), this is closely followed by the Environmental and Social Risk Management (Principle 1) (25%). None of the respondent banks seem to encounter any challenges implementing Principles 4, 6, and 7 – Women's Economic Empowerment, E&S Governance and Capacity Building respectively. However, about 25% of the respondents could not identify any challenges in implementing any of the principles.
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Some of the challenges identified by respondents are presented in Box 2 & Table 1 below:
Box 2: General Challenges Ÿ Inadequate resources, limited understanding of the principles and lack of Ÿ Ÿ
Ÿ Ÿ Ÿ Ÿ Ÿ Ÿ Ÿ Ÿ
enthusiasm and commitment Lack of management buy-in Singularity of the reporting template without consideration for the differences in operations of various financial institutions e.g. commercial vs. merchant banks and microfinance houses Lack of enabling environment for some of the principles Data gathering and verification Lack of knowledge/expertise in implementing, reporting and goal setting Getting stakeholders' buy-in and understanding. Difficulty measuring some environment footprints - solid waste, water Low level of awareness among customers, Lack of resources; knowledge gaps Financial Constraints, Capacity Building, Low awareness
Being relatively an emerging issue in the Nigeria banking space, most banks experienced implementation challenges including non-availability of necessary infrastructure to implement and monitor the progress of the principles, inadequate capacity in the relevant areas, resistance to change amongst others. However, significant progress has been made by the banks to address these initial challenges. As we speak, our records reveal that all banks have policies and procedures on NSBP in place. Substantial number of banks in the industry are doing quite well in the implementation of the NSBP while others are making concerted efforts to attain acceptable level of implementation. Dr. A'isha Usman Mahmood - Special Adviser to the CBN Governor on 'Sustainable Banking'
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Table 1: Speciď€ c Challenges CHALLENGES
PRINCIPLE
Resource Constraints
Principles 1 & 2
Lack of adequate data capturing systems
Principle 1 & 2
Lack of data and standardised approach required to report not available for some indices e.g. Co2 emissions
Principle 1 & 2
Ambiguity of Indices and absence of standard
Principle 1 & 2
Lack of proper measurement and reporting tools
Principle 2
Difficulty measuring some environment footprints e.g. Solid waste, water
Principle 2
Lack of a clear definition
Principle 1
Getting customers' buy-in
Principle 1
Reporting template not yet aligned with organisational and CSR strategies
Principle 9
PinPoints The Sustainable Banking office of the CBN and the International Finance Corporation (IFC) confirmed the major challenges institutions face with adoption and implementation to be the lack of infrastructure and limited capital resources. These tally with the challenges communicated by the respondent banks. In another view, some other financial experts listed major challenges to be the lack of management commitment and the reporting process. Nonetheless, an encouraging percentage of bank respondents expressed positive reviews about the adoption and implementation journeys.
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Some of the challenges noted include non- availability of requisite infrastructure to monitor and assess some parameters for measuring environmental footprints, capacity building and inadequate capital resources e.g implementing clean energy. Dr. A'isha Usman Mahmood - Special Adviser to the CBN Governor on 'Sustainable Banking' E&S risk management – this aspect is captured primarily by the Nigerian Sustainable Banking Principles 1. Assessing the Nigerian FIs, from this perspective, there has been good progress made on developing internal E&S policies, and procedures. According to the CBN, of 18 banks assessed in 2016, all had developed E&S policies and procedures which had been approved by their boards. However, the banks have faced challenges in implementing these policies and procedures primarily because of capacity constraints. Damilola Sobo, International Finance Corporation (IFC)
The major challenge lies with the leadership; there is need for top management commitment. The second challenge is in reporting‌ Prof. Ken Amaeshi - Political Economist and teacher of International Business at the University of Edinburgh Business School, UK
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Positive Respondent Reviews
The Principles have been easy to implement providing you adopt a robust defensible methodology. Anonymous
Fulfilment of the principles is a journey in and of itself and we are working towards it. Anonymous
My Institution has a well-defined structure, and has been getting better in terms of understanding and developing new techniques to ensure the report is done in an efficient manner, satisfactory and compliant with International Best practices. Anonymous 28 |(NSBP) A FIVE YEAR REVIEW
As part of the implementation, we have to also engage in customer awareness and education. Anonymous
Reporting All Banks must issue an initial Sustainable Banking report detailing their respective Principles implementation progress no later than 31 December, 2013. A full Sustainability Banking report will be required from each bank no later than 31 December 2014.
NSBP Guidance Note 2012, Page 4
The CBN issued on March 6, 2014, a reporting template captioned “Reporting Template for the Nigeria Sustainable Banking Principlesâ€? to enable eective monitoring of progress of implementation of the principles with a view to ensuring appropriate intervention to help resolve implementation challenges, and provide an objective, fair and equitable basis for possible incentives. The returns would also enable reporting institutions plan effectively, track the progress of their implementation against a roadmap and identify challenges for possible remedial action. Taking into cognizance that sustainable banking was a new concept in the banking industry, the reporting templates were structured in phases starting with three (3) quarterly one-off reports to Semi Annual and Annual reports. The three one-off reports were designed to cover the governance structure including the establishment of a sustainability unit, development of a sustainability policy and procedures while the Semi Annual and Annual reports cover the banks ongoing implementation of the NSBP along each of the Principles. We have received and reviewed the three one-off reports (June to Dec. 2014) and four Semi Annual reports starting June 2015. Dr. A'isha Usman Mahmood - Special Adviser to the CBN Governor on 'Sustainable Banking'
From our survey, 86% of the NSBP signatory respondent banks have submitted at least one report since adoption while only 14% have either not submitted any or are about to. This is progressively in line with the stipulation of the principles, requiring all signatories to put in place both internal and external reporting mechanisms. This may however be just in a bid to comply.
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About to 7% No 7%
Yes 86%
Yes
No
About to
7% of the respondent banks about to submit a report claimed to be in the compilation stage while the other 7% blamed non-submission on the lack of a reporting format.
PinPoints It is highly commendable that most respondent banks have submitted at least one report since adoption. This could be an indication that majority of the institutions that have adopted the NSBP have submitted a form of implementation report, as expected of them by the CBN and as stipulated by the NSBP Guidance Note. This could imply a strong commitment by the institutions whilst it strengthens the trajectory of sustainable banking in Nigeria. Besides, the fact that the CBN mandates the institutions to submit a report on their progress with the principles may have been a catalyst for the commitment displayed by them. Furthermore, the issuance of a CBN reporting template in 2014 is progressive although it is surprising that some institutions are still unaware of it.
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Table 2: Breakdown of Report Submission to CBN
NUMBER OF REPORTS
NUMBER OF RESPONDENT BANKS
9
1
7
2
5
3
4
4
1
1
Semi-annual reports since 2013
1
Compliance and Reporting Process Interestingly, half of the respondent banks considered the compliance and reporting process straightforward and the other half considered it complicated.
Compliance and Reporting Process
Complicated 50%
Straightforward 50%
Straightforward
Complicated (NSBP) A FIVE YEAR REVIEW | 31
Box 3: Challenges with Reporting Ÿ Acceptability Ÿ CBN's rigid approach with its reporting template Ÿ Ambiguity of some requests/matrix Ÿ Delay in response from internal stakeholders Ÿ Meeting up with timelines Ÿ Gathering information and stakeholder engagement Ÿ Lack of understanding about relevance Ÿ Difculty in gathering data especially for NSBP 2 (Environmental and Social
Footprint) Ÿ Lack of knowledge and standardised tools for reporting certain indices, especially
those pertaining to NSBP 1 and 2 Ÿ Lack of training
PinPoints Findings reveal that the biggest challenge respondent banks face with reporting is difficulty with proper implementation. The transition from compliance driving sustainable banking, to commitment and full adoption of the NSBPs requires capacity and training on all levels within the bank. A true understanding of the business case for sustainable banking will lead to full implementation of E&S policies and procedures, and encourage innovation around the NSBPs. Damilola Sobo, International Finance Corporation (IFC) It is also important to reveal that the approach on the implementation of the principles has been persuasive up until now. To this end, the CBN has not sanctioned banks on the implementation of the NSBP. The CBN is however considering incentives for banks assessed to have made considerable progress in adopting the principles.
32 |(NSBP) A FIVE YEAR REVIEW
Relevance of NSBP (Suitability for Sustainable Banking)
Maybe 31%
Yes 69%
Yes
Maybe
According to the classification of the International Finance Corporation's Sustainable Banking Network (SBN), Nigeria's approach to sustainable banking falls under the blend of industry-led initiatives and policy leadership at different stages of sustainable development, through a set of mandatory policies. This approach is similar to that of Brazil. From findings, 69% of the respondents are confident in the credibility of the NSBP as an effective driver of sustainable banking in Nigeria. However, about 31% expressed uncertainty in the capacity of the principles in effectively promoting sustainable banking in Nigeria. The recorded percentage for doubt may be connected to the numerous challenges respondent banks identified in implementation. Similarly, international finance experts expressed confidence in the suitability of the NSBP in meeting the sustainable banking needs of the Nigerian market, as well as its uniqueness and credibility in the international finance space.
(NSBP) A FIVE YEAR REVIEW | 33
I think international standard varies but if the question is if they meet our local needs then I would say yes. Although the sincerity behind the principles and the adoption is still very poor. What we have in Nigeria is good enough for our market/environment. However, it needs to be tweaked a bit and made more relevant for Nigeria. It is about 80% okay but we can do more on it. Prof. Ken Amaeshi - Political Economist and teacher of International Business at the University of Edinburgh business school, UK
The principles were developed using international standards such as IFC's Performance Standards, World Bank Group EHS guidelines and Equator Principles as starting points or benchmarks in the design phase. It is important that these frameworks are used as guidance, and aligned with country level legislations and institutional systems. In addition, the NSBP process was consultative during the developmental phases, and subsequently the development of a steering committee comprised of the E&S champions of all the banks, and the Central Bank, has been effective in ensuring that the NSBPs remain relevant, and pertinent for the sector. Damilola Sobo, International Finance Corporation (IFC)
PinPoints Findings reveal that the NSBP is a good step towards sustainable banking in Nigeria if properly implemented. It is however obvious that financial institutions have to clearly communicate to the regulatory body, (CBN) the challenges faced at the implementation phases. Moreover, there is need for a re-evaluation of each challenge expressed or submitted by all institutions to the CBN, in order not to jeopardise the main objective of the principles, which is to promote sustainable banking in Nigeria. This implies that NSBP Implementation challenges must be tackled for there to be effective sustainable banking practices in Nigeria.
34 |(NSBP) A FIVE YEAR REVIEW
Relevance to Institutions Maybe 19%
Yes 81%
Yes
Maybe
81% of the respondents reported that the NSBP is relevant for their type of institution; this percentage included both those who have adopted the principles and those who have not. On the flip side, 19% of the respondents are uncertain of their position. About 14% of respondents who are uncertain are Development Finance Institutions while about 5% are Commercial Banks.
PinPoints Development Finance Institutions seem to be most bothered by the relevance of the NSBP to their structure and operations. Notwithstanding, results from respondent banks as well as insight from financial experts and the CBN indicate the suitability of the NSBP for all types of financial institutions. However, there may be the need for a modification to suit the structure and operations of every type of financial institution. From another angle, although the CBN is working at ensuring the participation of other financial institutions, especially the Microfinance banks, in the implementation of the NSBP; non-banking financial institutions such as Insurance, Pension Funds, and Capital Market firms have developed a similar version; The Sustainable Finance Principles. For instance, there is a National Roadmap on Sustainable Finance developed and adopted by members of the Financial Services Regulation Coordinating Committee (FSRCC), to ensure a balance between economic prosperity, environmental protection and social development. (NSBP) A FIVE YEAR REVIEW | 35
Non-banking financial institutions (NBFI) such as microfinance banks, insurance, private equity and pension funds can also integrate environmental and risk management considerations into their business models and lending processes. For example PE funds can develop energy and resource requirements for their investee companies, pension funds can invest in green bonds, etc. The NSBPs as they are may not be directly applicable to the NBFIs, but guidelines on the scope of the applicability to their businesses should be considered for development. Damilola Sobo, International Finance Corporation (IFC)
Impact Maybe 20%
Yes 80%
Yes
Maybe
Interestingly, despite the scores of challenges reportedly encountered in the implementation of the principles, 80% of the respondents still reported that they have realised some form of sustainable benefits from their implementation of the NSBP and investments in each principle. 20% however indicated uncertainty about the impact the adoption and implementation has impressed on the sustainability of their institutions. This may not be unconnected with the period of adoption, given that a few of the banks only adopted the principles a year or few months ago.
PinPoints Although the scope of this study does not investigate the form of benefits; either financial or nonfinancial, it is however progressive that majority of the institutions have enjoyed some form of positive impact on the sustainability of their organisations since the adoption of the principles. 36 |(NSBP) A FIVE YEAR REVIEW
The CBN has initiated a brilliant framework in the NSBP, as we are all now aware of the need to ensure business is done in a manner that would not hinder the unborn generation from making business deals. NSBP has also stressed the need to ensure that business footprints are minimal as possible, evident from the early closure policies and the work-from-home initiates taken by DMBs. -Respondent
Benefits to Institutions Some of the benefits highlighted(copied verbatim) as associated with incorporating sustainability into financial strategy and business practices are:
Ÿ An opportunity for innovation; Ÿ Presents a business case Ÿ There is a correlation between sustainability and loan performance in the banking
industry. Banks that adopted sustainable practice in their business activities therefore have more quality loans than otherwise banks. Ÿ Banks with sound sustainability practices can have easier access to capital from International Finance Institutions. These sustainably practices are requisite requirement for those foreign loans. Ÿ Banks with strong ethical and sustainable practices stand better chances of high patronage including the capital market.
Drivers for ESRM were largely and evidently associated with the requirements from development finance institutions (DFIs), shareholders and international parent companies (i.e., international requirements). Other drivers such as the improved reputation and credibility; opportunities for an improved portfolio; economic incentives associated with cost reduction and accessing new market opportunities were also recognized as advantages associated with ESRM by some individual Fis. The role of DFIs and the international ESRM requirements associated with their investments/ funding, play a critical role in embedding sustainability elements in the projects that FIs support. There is an opportunity to raise awareness around the benefits of ESRM and the business opportunities associated with sustainable finance to leverage the drivers beyond international requirements. Excerpt from an IFC report “Global Survey on Factors affecting Environmental and Social Risk Management of banks in emerging markets”
(NSBP) A FIVE YEAR REVIEW | 37
Externalities 33% of the respondents reported that the current economic situation of the country affects or has affected their institution's adherence of the NSBP and subsequently sustainable banking. However, 47% did not agree that the state of the economy has negatively influenced the performance of their responsibilities towards the NSBP or sustainable banking while 20% were indifferent about the effects of the dwindling economy on the implementation or adherence to the tenets of the principles cum sustainable banking in general. Reduction in budgetary allocation towards investment in the implementation of the principles was the sole concern identified by the respondents having been negatively affected by the current state of the economy.
Maybe 20%
Yes 33%
No 47%
Yes
No Maybe
Impact on Nigeria Key findings from respondent interviews reveal that although Nigeria may not have recorded the impact of the NSBP/sustainable banking within the last five years, there have been many envisaged direct benefits to the local communities. Also,there are prospects, considering the perceived commitment of both the CBN and the Banker's Committee to the pursuit of sustainable banking in the country. However, the scope of this study does not cover the investigation of specific impact recorded. 38 |(NSBP) A FIVE YEAR REVIEW
Future Projections Need for a Review Indifferent 13%
No 20%
Yes 67%
Yes
No
Indifferent
Box 4: Industry Views
Do you think the Nigerian Sustainable Banking Principles are due for a review and in what areas?
CBN
IFC
Expert
No, not yet
As with any policy and strategy, it is important that periodic review of the policy be undertaken to identify what has worked, what the challenges are, and the available opportunities. Such a re v i e w s h o u l d b e agreed and led by the Steering Committee.
There should be a f o c u s o n implementation of the principles and the key to implementation is reporting therefore, there should also be a focus on reporting. Reporting should be driven by globally acceptable standards.
(NSBP) A FIVE YEAR REVIEW | 39
PinPoints There is obviously no consensus amongst all signatories on the review of the NSBP. This could hamper its objectives. There is therefore need for robust engagement by all the stakeholders for sustainable banking to be attained in the country. The Guidance Note for the implementation of the principles however explains its provisions and conditions for a review: We recognise that we may not get everything right the first time. We will review these principles on an annual basis based on our implementation experience, and in order to reflect on-going learning and emerging good practice. We will thus seek to evaluate and report on an annual basis our individual bank as well as collective sector progress against the principles. We will celebrate our successes and acknowledge our progress whilst remaining mindful; of areas requiring improvement. -
Page 3, Guidance Note, Final Version, July 2012
Suggested Improvements
The Principles
The Guidelines
Implementation
Monitoring
Reporting
40 |(NSBP) A FIVE YEAR REVIEW
Although not all the respondents agree that the principles are due for a review, there is a consensus on the need for improvements. A key aspect identified as requiring major improvement and review is the reporting format. This is followed by the monitoring and implementation and far behind are the Guidelines and the Principles.
Respondent Recommendations Some of the key suggestions by respondents towards improving the NSBP included: communication to end users, improvement in monitoring process, review of principles and reporting format, sensitisation for microfinance institutions, collaboration between financial institutions and other stakeholders, and incentives for implementation.
Box 5: Respondent Recommendations (copied verbatim) Ÿ Communication of the ideals of NSBP to end users. Ÿ Putting in place solid frameworks/resources to aid understanding of the benefits of
Ÿ Ÿ Ÿ Ÿ Ÿ Ÿ Ÿ Ÿ Ÿ Ÿ
Ÿ
Ÿ
sustainable banking, consequently propelling genuine commitment and drive on the part of organisations. Better management buy-in. Different institutions need to have templates that is tailor-suited for the nature of their business/operations as opposed to a singular template across the institutions. The Apex Bank should improve on the monitoring process to make it compulsory for all the financial institutions to report. A review of current principles and reporting. Sensitisation of more microfinance institutions. Principles should be clearly defined. The reporting requirements should be tailored to address specific organisations and should not be one size fits all. Increased collaboration between financial institutions and mainstreaming of enduring sustainable culture change management. Conduct of a detailed verification of Reports submitted by Banks to the CBN. Once there is that sense, monitoring, data integrity of the reports will improve. With continued collaboration with other stakeholders such as FERMA, NESRA, MAN. etc, E&S risk management practices would be much more easier to enforce on companies whose activities pose high risk issues for their employees, environment and project community. All relevant stakeholders and experts need to have a session to review all principles, the applicability and relevance. This is to be followed with a training and uniform tools to be deployed by all banks. The regulatory bodies within the Country should encourage the adoption of the NSBPs through rewards and recognitions. Sanctions should also be deployed for defaulting institutions (NSBP) A FIVE YEAR REVIEW | 41
Expert Recommendations Key recommendations by interviewed experts towards ensuring that proper implementation of the principles translates to sustainable banking included: Ÿ Training: Training has been identified as a gap for the banks, and it is important that
banks realize this gap and develop a strategy to train, and ensure the training is being taken on board by their staff. Ÿ CBN should task institutions to adopt reporting standards like the GRI instead of
creating local standards for implementation and reporting. Ÿ Financial Institutions should believe in the principles and leave up to it. They need to
also realise that good leadership is essential to attaining sustainable banking through the NSBP. There is also need for top management commitment.
CONCLUSION
Has the NSBP Driven Any Significant Improvement within Five Years? This study investigated the state of the Nigerian Sustainable Banking Principles (NSBP) within the five years of its adoption, as well as its prospect for driving sustainable banking in Nigeria. It considered the structure, adoption, implementation, reporting, relevance, impact, and future projection. Overall, the study reveals that although Nigeria may not have visibly recorded the impact of the NSBP/sustainable banking within the last five years, there have been some form of direct benefits to the local communities where the businesses are situated as well as benefits to the financial institutions. It also reveals that the CBN and signatory institutions are committed to the principles and have confidence in it as a catalyst for sustainable banking in Nigeria. Moreover, the International Finance Corporation (IFC) also expresses confidence in the principles as a potential driver of sustainable banking in Nigeria, if properly implemented. These imply that there is a prospect for sustainable banking in Nigeria through the instrument of NSBP. Nevertheless, all the respondent banks acknowledge the need for an improvement in the implementation of the principles. Lack of infrastructure and limited resources are the major challenges expressed by the institutions and expert bodies, as facing proper implementation. Key findings are highlighted below: Ÿ Most institutions have dedicated officers who coordinate the implementation of the Ÿ Ÿ Ÿ Ÿ Ÿ
Ÿ
Ÿ
NSBP. This is in line with the stipulations of the adoption; 94% of the respondents are aware of the NSBP and only 6% from the Micro-finance sector are unaware; 88% of respondent banks have adopted the NSBP and the remaining 12% who haven't are Microfinance banks; All twenty six (26) deposit money banks who are signatories have adopted and are at different stages of implementation; 86% of respondents are satisfied with the role of the CBN in the adoption process; Principles four (4) and six (6) – Women Economic Empowerment and E&S Governance, respectively, appear to have recorded the most success in implementation for the respondent institutions that have adopted the principles. Principles two (2) and one (1) – Environmental and Social Footprint and Environmental and Social Risk Management, respectively, have proven most challenging to implement for respondent institutions; Lack of infrastructure and limited resources are the major challenges expressed by the institutions and expert bodies, as facing proper implementation;
44 |(NSBP) A FIVE YEAR REVIEW
Ÿ 86% of NSBP signatory banks have submitted at least one report to the CBN since Ÿ Ÿ Ÿ Ÿ Ÿ Ÿ Ÿ
Ÿ Ÿ
adoption; 50% of respondent banks considered the compliance and reporting process straightforward and the other 50% consider it complicated; Respondents attributed the challenge with reporting to difficulty with implementation; 69% of the respondents are confident in the credibility of the NSBP as a driver of sustainable banking in Nigeria, if properly implemented; 81% of respondents reported that the NSBP is relevant for their type of institution; Development Finance Institutions seem to be most bothered by the relevance of the principles to their structures and operations; 80% of respondent banks have realized some form of benefits from their implementation of the NSBP and investments in it; Only 33% of respondents lamented that the current economic situation of the country has affected/affects their implementation of the NSBP, majorly in the form of reduction in budgetary allocation; 67% of respondent banks called for a review of the principles whilst the CBN Sustainable Banking Office does not think they are due for a review; Reporting format, monitoring and implementation are top 3 aspects respondents requested for improvements on.
From these findings,it has become apparent that although the NSBP is a right direction towards sustainable banking in Nigeria, proper implementation must be upheld for its success not to bejeopardised.
(NSBP) A FIVE YEAR REVIEW | 45
RECOMMENDATIONS
Close infrastructural and resource gap through greater management commitment. commitment The biggest challenges for the implementation of the NSBP, from the study is the lack of infrastructure and limited resources. This infrastructural gap is more evident in the performance of Principles 1 and 2. Many respondent banks expressed concerns over difficulty in measuring and reporting on their environmental footprints, as well as capturing potential E&S Risks. There are, however, various tools that financial institutions can invest in to aid the assessment and measurement of environmental footprints. Nevertheless, this can only be achieved if sustainability issues are indeed prioritised by the top management of the institutions. In addition, the CBN in conjunction with international finance organisations such as the IFC, UNEP-FI, UNGC, should be engaged for the provision constant and adequate capacity trainings and/or funding to financial institutions, to support the proper implementation of the principles. This is particularly imperative for Microfinance banks who are either still in their early stages of implementation or are yet to adopt the principles.
Stakeholder Engagement on the Principles Stakeholders' limited understanding of the principles, lack of commitment and enthusiasm, lack of management buy-in and low level of awareness among customers cum difficulties getting their buy-in are some of the most articulated challenges with the implementation of the principles. Howbeit, the support and active participation of stakeholders can only be secured when they are adequately engaged. In order to achieve this, an introduction of periodic stakeholder consultative and informative forums is imperative. Moreover, constant public awareness on the principles via the media and bank-wide information platforms is now exigent.
Monitoring Framework Although progressive that most of the signatory institutions have submitted at least one report since adoption, it is difficult to ascertain the credibility of these reports vis a vis reality–reporting for compliance or reporting real activities. It is pertinent that the regulatory body puts in place working monitoring frameworks to ensure that reports tally with what is on ground.
(NSBP) A FIVE YEAR REVIEW | 47
Peer Review Mechanism One of the approaches international conventions and principles have employed to assist signatory parties in effective implementation is the institution of peer review mechanisms where parties peer-review the implementation of principles. It is also an instrument for monitoring performance among signatories as well as a self-assessment mechanism. Clearly, the NSBP are due for peer review in order to further promote the purpose of creation, help signatories identify mutual challenges and substantiate specific needs/assistance for implementation, provide the regulatory body with constant information on progress and challenges, and facilitate the exchange of information amongst signatories, as well as serve as a monitoring and evaluation tool.
A review of the NSBP may be necessary Based on the projections of the Bankers Committee, “We recognise that we may not get everything right the first time. We will review these principles on an annual basis based on our implementation experience, and in order to reflect on-going learning and emerging good practice� and the evident challenges expressed by the respondent banks on implementation, it may be pertinent the Bankers Committee and the regulatory body (CBN) consider a review of the principles. A review will address most of the concerns with implementation, monitoring, reporting, and suitability for all types of financial institutions and subsequently translate the success of the NSBP into sustainable banking. This review should however be carried out with input from all stakeholders, including investors and the civil society, who need to be actively engaged and adequately informed.
48 |(NSBP) A FIVE YEAR REVIEW
APPENDIX
List of Signatories* Central Bank of Nigeria Nigeria Deposit Insurance Corporation Access Bank Associated Discount House Ltd. Bank of Agriculture Bank of Industry CitiBank Nigeria Limited Consolidated Discounts Ltd. Diamond Bank Plc. Ecobank Plc. Enterprise Bank Ltd. . Express Discounts Ltd Federal Mortgage Bank of Nigeria Fidelity Bank Plc. First Bank of Nigeria Plc. First City Monument Bank Plc. First Securities Discount House Ltd. Guaranty Trust Bank Plc. Jaiz Bank Kawaka Discounts House Ltd. Keystone Bank Ltd. Mainstreet Bank Ltd. Nigeria Agricultural Cooperative and Rural Development Nigeria Export Import Bank Skye Bank Plc. Stanbic IBTC Bank Plc. Standard Chartered Bank Nigeria Ltd. Sterling Bank Plc. Union Bank of Nigeria Plc. United Bank of Africa Plc. Unity Bank of Nigeria Plc. Urban Development Bank of Nigeria Plc. Wema Bank Plc. Zenith Bank Plc.. Â *Institutions that adopted the principles at 2012
50 |(NSBP) A FIVE YEAR REVIEW
REFERENCES CBN (2012), Nigerian Sustainable Banking Principles: Final Version Deloitte (2017): Sustainability Banking as a Driver for Growth: Deloitte (May 2017) IFC (2017): Greening the Banking System: Experiences from the Sustainable Banking Network: Background Paper for the G20 Green Finance Study Group Olaf Weber (2012): Sustainable Banking: History and Current Developments: Working Paper: University of Waterloo http://www.transcampus.org/JORINDV7Dec2009/JournalsV7NO2Dec20093.html http://3blmedia.com/News/CSR/Nigerian-Sustainable-Banking-Principles-Paving-way-Responsible-BusinessNigeria https://www.iisd.org/business/banking/sus_timeline.aspx
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