SBFN Member Since:
2016
Member Organisations
Bank of Ghana
Ghana Association of Bankers
Progress Against sub Pillars
Framework Documents
| Country | Policies/ Principles/ Guidelines | Year | Issuer |
|---|---|---|---|
| Ghana | 2019 | Bank of Ghana | |
| Ghana | 2019 | Bank of Ghana | |
| Ghana | 2019 | Bank of Ghana | |
| Ghana | 2019 | Bank of Ghana | |
| Ghana | 2019 | Bank of Ghana | |
| Ghana | 2019 | Bank of Ghana | |
| Ghana | 2018 | Bank of Ghana |
Pillar 1 - ESG Integration - Strategic Alignment
National Framework
P 1.1 – Has the regulator or industry association published a national framework (“Framework”) for the banking sector that sets out expectations for integrating the consideration of environmental, social, and governance (ESG) risks and performance?
Yes
Source Reference Detail
Guidance principles developed by BOG, GAB and EPA and adopted by the banking industry. These Priciples would in the future be adopted by the other financial insitituions within the system.e.g Specialised Deposit-taking Institutions (SDIs)
Source Reference Document
Sustainable Banking Principles
Source Reference Description
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P 1.2 – Has the relevant regulator or industry association published a Framework for capital markets, investment, insurance or other non-lending FIs that sets out expectations for integrating the consideration of environmental, social, and governance (ESG) risks and performance?
No
Source Reference Detail
–
Source Reference Document
–
Source Reference Description
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Pillar 1 - ESG Integration - Strategic Alignment
Alignment with International Goals & Standards
P 1.3 – Does the Framework make reference to international sustainable development frameworks or goals?
Yes
Source Reference Detail
SDG, Principles of Responsible Banking (PRB), Equator Principles.IFC performance Standards, Principles of Responsible Investments (PRI), Climate Change
Source Reference Document
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Source Reference Description
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P 1.4 – Does the Framework make reference to established international ESG risk management standards and principles for FIs??
Yes
Source Reference Detail
Guidance principles developed by BOG, GAB and EPA and adopted by the banking industry. These Priciples would in the future be adopted by the other financial insitituions within the system.e.g Specialised Deposit-taking Institutions (SDIs)
Source Reference Document
Sustainable Banking Principles
Source Reference Description
A to D
Pillar 1 - ESG Integration - Strategic Alignment
Alignment with national goals & strategies
P 1.5 – Does the Framework make reference to specific national development objectives, plans, policies, goals, or targets?
Yes
Source Reference Detail
–
Source Reference Document
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P 1.6 – Does any cooperation exist between agencies or between the regulator and industry association with respect to policy design and/or implementation related to ESG integration?
Yes
Source Reference Detail
–
Source Reference Document
Sustainable Banking Principles
Source Reference Description
A to E
P 1.7 – Does any inter-agency data sharing currently exist related to ESG integration by FIs?
No
Source Reference Detail
–
Source Reference Document
–
Source Reference Description
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Pillar 1 - ESG Integration - Regulatory and Industry Association Actions
Overall Approach & Strategy
P 1.8 – Does the Framework provide guidance on the role of the regulator or industry association with regard to assessing and managing ESG risk and performance in the financial sector?
Yes
Source Reference Detail
Regulator is reponsible for ensuring full implementation of the Principles whiles industry assocaition will ensure it adoption
Source Reference Document
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Source Reference Description
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P 1.9 – Has the regulator or industry association undertaken market assessment to identify systemic ESG risks through analysis of the portfolios of supervised entities/members and published the results?
Yes
Source Reference Detail
This was done at the initial stage of the project in 2015.
Source Reference Document
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Source Reference Description
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Pillar 1 - ESG Integration - Regulatory and Industry Association Actions
Technical Guidance
P 1.10 – Does the Framework provide technical guidance or tools to support implementation of ESG risk and performance management by the financial sector?
Yes
Source Reference Detail
Sector Guidance Notes provided for five specific sectors.
Source Reference Document
Sustainable Banking Principles
Source Reference Description
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Pillar 1 - ESG Integration - Regulatory and Industry Association Actions
Supervisory Activities & incentives
P 1.11 – Is the implementation of the Framework regularly monitored and/or information regularly collected from FIs by the regulator and/or industry association?
Yes
Source Reference Detail
Templates have been developed and shared with banks for the submission of information. First data request expected by end of first quarter 2021.
Source Reference Document
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P 1.12 – Does the regulator or industry association provide any financial or non-financial incentives for FIs to manage ESG performance as part of the Framework?
No
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P 1.13 – Does the regulator or industry association apply any disincentives/penalties for non-compliance by FIs in terms of expectations from the regulator and/or industry association related to ESG risk management as part of the Framework?
No
Source Reference Detail
–
Source Reference Document
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Source Reference Description
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Pillar 1 - ESG Integration - Regulatory and Industry Association Actions
Tracking & Aggregated Disclosure
P 1.14 – Has the regulator or industry association established a data collection approach and database to track or regularly publish data related to ESG integration by FIs as part of the Framework?
Yes
Source Reference Detail
The principles as has been stated in the policy document will be driven by strong governance and risk mamangement systems within banks. This is also supported by the Bank’s corporate governance directive document issued in december 2018 which defined a Key Management Personel. “Key Management Personnel” means the chief executive officer or managing director, deputy chief executive officer, chief operating officer, chief finance officer, Board secretary, treasurer, chief internal auditor, the chief risk officer, the head of compliance, the anti-money laundering reporting officer, the head of internal control functions, the chief legal officer, the manager of a significant business unit of the a Regulated Financial Institution
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Source Reference Description
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Pillar 1 - ESG Integration - Expectations of FI Actions
Strategy & Governance
P 1.15 – Does the Framework require/ask the FI’s board of directors (or highest governing body) to approve an ESRM and/or ESG integration strategy, and to supervise its implementation?
Yes
Source Reference Detail
The principles as has been stated in the policy document will be driven by strong governance and risk mamangement systems within banks. This is also supported by the Bank’s corporate governance directive document issued in december 2018 which defined a Key Management Personel. “Key Management Personnel” means the chief executive officer or managing director, deputy chief executive officer, chief operating officer, chief finance officer, Board secretary, treasurer, chief internal auditor, the chief risk officer, the head of compliance, the anti-money laundering reporting officer, the head of internal control functions, the chief legal officer, the manager of a significant business unit of the a Regulated Financial Institution
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Pillar 1 - ESG Integration - Expectations of FI Actions
Organizational Structure & Capacity Building
P 1.16 – Does the Framework require/ask FIs to allocate resources/budget commensurate with portfolio ESG risks and define roles and responsibilities for ESG integration within the organization?
Yes
Source Reference Detail
The Board, Management Teams, CROs
Source Reference Document
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Source Reference Description
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P 1.17 – Does the Framework require/ask FIs to develop and maintain the ESG expertise and capacity of staff commensurate with portfolio ESG risks through regular training and learning?
Yes
Source Reference Detail
Training programs have been developed in line with the Principles to support industry in the implemetation
Source Reference Document
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Source Reference Description
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P 1.18 – Does the Framework require/ask FIs to create incentives for managers to reduce the ESG risk-level of the portfolio over a specified timeframe?
No
Source Reference Detail
–
Source Reference Document
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Pillar 1 - ESG Integration - Expectations of FI Actions
Policies & Procedures
P 1.19 – Does the Framework require/ask FIs to develop policies and procedures to identify, classify, measure, monitor, and manage ESG risks and performance throughout the financing cycle at the client level and/or the transaction/project level?
Yes
Source Reference Detail
Yes: A to H: these issues have been comprehensively addressed in the framework
Source Reference Document
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Source Reference Description
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P 1.20 – Does the Framework require/ask FIs to undertake a regular review and monitoring of ESG risk exposure at aggregate portfolio level?
Yes
Source Reference Detail
–
Source Reference Document
–
Source Reference Description
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P 1.21 – Does the Framework require/ask FIs to establish and maintain an external inquiry/complaints/grievance mechanism for interested and affected stakeholders in relation to ESG practices?
Yes
Source Reference Detail
–
Source Reference Document
–
Source Reference Description
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Pillar 1 - ESG Integration - Expectations of FI Actions
Tracking, Reporting & Disclosure
P 1.22 – Does the Framework require/ask FIs to report ESG risks and performance to the regulator or industry association?
Yes
Source Reference Detail
–
Source Reference Document
–
Source Reference Description
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P 1.23 – Does the Framework require/ask FIs to report on ESG integration publicly?
Yes
Source Reference Detail
This is addressed under Principle 7
Source Reference Document
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Source Reference Description
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P 1.24 – Does the Framework require/ask FIs to track credit risk (e.g. loan defaults) and/or financial returns in relation to ESG risk level?
Yes
Source Reference Detail
Addressed under Principle 1, reference is made to the policy document.
Source Reference Document
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Source Reference Description
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Pillar 2 - Climate Risk Management - Strategic Alignment
National Framework
P 2.25 – Has the regulator or industry association published a national framework (“Framework”) for the banking sector that sets out expectations for integrating the consideration and management of climate risks and their impact in the national economy?
Yes
Source Reference Detail
Bank of Ghana Sustainable Banking Principles and Sector Guidance Notes (2019) as ESG foundation for the further elaboration of climate-related risks (Bank of Ghana has signaled intention to further develop climate risk approach). Principle 1 E&S Risk Management references climate change and GHG emissions (Page 18); Principle 6 Resource Efficiency and Sustiainable Production and Consumption references cliamte in the context of adaptation financing (Page 48;) Principle 7 Reporting references the TCFD. Sector Guidelines for Agriculture and Forestry section reference GHG emissions from land clearing and deforestation, and related financial impacts on agircultural yields and impacts on natural carbon sinks (Page 72-74); Sector Guidelines for Power Generation and Oil, Gas and Mining reference GHGs and climate (pages 132 and 155); Sector Guidelines for Real Estate reference climate proofing assets for flooding and business disruption (Page 194).
Source Reference Document
Sustainable Banking Principles
Source Reference Description
Refer to description
P 2.26 – Has the relevant regulator or industry association published a Framework for capital markets, investment, insurance or other non-lending FIs that sets out expectations for integrating the consideration and management of climate risks and their impact in the national economy?
No
Source Reference Detail
–
Source Reference Document
–
Source Reference Description
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Pillar 2 - Climate Risk Management - Strategic Alignment
Alignment with International Goals & Standards
P 2.27 – Does the Framework make reference to international agreements or frameworks to address climate?
Yes
Source Reference Detail
References Paris Agreement and Sustainable Development Goals (Page 2).
Source Reference Document
Sustainable Banking Principles
Source Reference Description
References Paris Agreement and Sustainable Development Goals (Page 2).
P 2.28 – Does the Framework recognize or align with established regional or international good practice for climate risk management and disclosure by FIs?
Yes
Source Reference Detail
References the Taskforce on Climate-related Financial Disclosures (TCFD).
Source Reference Document
Sustainable Banking Principles
Source Reference Description
Principle 7
Pillar 2 - Climate Risk Management - Strategic Alignment
Alignment with National Goals & Strategies
P 2.29 – Has the regulator or industry association aligned the Framework with national goals to address climate change in line with the country’s Nationally Determined Contributions (NDCs) to the Paris Agreement?
Yes
Source Reference Detail
References the Paris Agreement and actions in Ghana (Foreword, Page 5-6) and identify priority sectors for climate action including GHG intensive sectors (Oil, Gas, and Mining, Power Generation, Manufacturing, Agriculture and Forestry).
Source Reference Document
Sustainable Banking Principles
Source Reference Description
Refer to description
P 2.30 – Does any cooperation exist between agencies, or between government and industry association, with respect to policy design or implementation related to climate risk management?
Yes
Source Reference Detail
References industry-regulator collaboration including the Bank of Ghana (BoG), Ghana Association of Bankers (GAB) and Ghana Environmental Protection Agency (EPA), in addition to international organizations (Foreword, Pages 3-4).
Source Reference Document
Sustainable Banking Principles
Source Reference Description
Refer to description
P 2.31 – Does any inter-agency data sharing currently exist related to climate risk management by FIs?
No
Source Reference Detail
–
Source Reference Document
–
Source Reference Description
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Pillar 2 - Climate Risk Management - Regulatory and Industry Association Actions
Overall Approach & Strategy
P 2.32 – Has the regulator or industry association undertaken research on historical impacts to the economy and financial sector from climate change, and/or future expected impacts resulting from physical and transition climate risks?
No
Source Reference Detail
–
Source Reference Document
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Source Reference Description
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P 2.33 -Does the Framework identify key sources of GHG emissions – such as in particular sectors – as priorities in the proactive management of climate risks by the financial sector?
Yes
Source Reference Detail
References GHG emissions from land clearing and deforestation, and related financial impacts on agircultural yields and impacts on natural carbon sinks (Page 72-74); Sector Guidelines for Power Generation and Oil, Gas and Mining reference GHGs and climate (pages 132 and 155); Sector Guidelines for Real Estate reference climate proofing assets for flooding and business disruption (Page 194).
Source Reference Document
Agriculture and Forestry Sector Guidance Note
Source Reference Description
Refer to description
P 2.34 – Does the Framework incorporate the conservation/restoration of natural carbon sinks (such as oceans, forests, mangroves, grasslands, and soils) as an important part of reducing climate change risks? (e.g., through guidelines, scenario analysis, targets, or incentives for FIs)
Yes
Source Reference Detail
References GHG emissions from land clearing and deforestation, and related financial impacts on agircultural yields and impacts on natural carbon sinks (Page 72-74); Sector Guidelines for Power Generation and Oil, Gas and Mining reference GHGs and climate (pages 132 and 155); Sector Guidelines for Real Estate reference climate proofing assets for flooding and business disruption (Page 194).
Source Reference Document
Agriculture and Forestry Sector Guidance Note
Source Reference Description
Refer to description
P 2.35 – Has the regulator or industry association developed an internal strategy to address climate risk, and/or embedded climate risk management into its governance, organizational structures, and budget as part of the Framework?
No
Source Reference Detail
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Source Reference Document
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Source Reference Description
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P 2.36 – Has the regulator or industry association undertaken any activities to expand and deepen analytical understanding of national and/or cross-border physical and transition climate risks, and to raise awareness as to how these risks may transmit to, and impact, the financial sector?
No
Source Reference Detail
–
Source Reference Document
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Pillar 2 - Climate Risk Management - Regulatory and Industry Association Actions
Technical Guidance
P 2.37 – Has the regulator or industry association developed risk assessment approaches, methodologies, or tools to understand and assess the financial sector’s exposure to climate risk as part of the Framework?
No
Source Reference Detail
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Source Reference Document
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Pillar 2 - Climate Risk Management - Regulatory and Industry Association Actions
Supervisory Activities & Incentives
P 2.38 – As part of the Framework, has the regulator clarified supervisory expectations with regard to climate risk management by FIs, including consideration of international good practices?
No
Source Reference Detail
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Source Reference Document
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P 2.39 – Has the regulator started to explicitly embed climate-related risk in supervisory activities and review processes as part of the Framework?
No
Source Reference Detail
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Source Reference Document
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P 2.40 – Has the regulator started to explicitly embed climate-related risk in supervisory activities and review processes as part of the Framework?
No
Source Reference Detail
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Source Reference Document
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P 2.41 – Has the regulator started to explicitly embed climate-related risk in supervisory activities and review processes as part of the Framework?
No
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Pillar 2 - Climate Risk Management - Regulatory and Industry Association Actions
Tracking & Aggregated Disclosure
P 2.42 – Does the regulator or industry association regularly collect and/or report market-level and/or FI-level data on climate-related financial sector risks as part of the Framework?
No
Source Reference Detail
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Source Reference Document
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Source Reference Description
Pillar 2 - Climate Risk Management - Expectations of FI Actions
Strategy & Governance
P 2.43 – Does the Framework require/ask FIs to establish a strategy for climate risk management with responsibility at the board of director level (or highest governing body)?
No
Source Reference Detail
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Source Reference Document
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Pillar 2 - Climate Risk Management - Expectations of FI Actions
Organizational Structure & Capacity Building
P 2.44 – Does the Framework require/ask FIs to define the roles and responsibilities and related capacities of the FI’s senior management and operational staff in identifying, assessing, and managing climate-related financial risks and opportunities?
No
Source Reference Detail
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Source Reference Document
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Pillar 2 - Climate Risk Management - Expectations of FI Actions
Policies & Procedures
P 2.45 – Does the Framework require/ask FIs to expand existing risk management processes to identify, measure, monitor, and manage/mitigate financial risks from climate change?
No
Source Reference Detail
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Source Reference Document
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Pillar 2 - Climate Risk Management - Regulatory and Industry Association Actions
Tracking, reporting & disclosure
P 2.46 – Does the Framework require/ask FIs to report on their overall approaches to climate risk management in line with international good practices (e.g., TCFD), or establish a timeline by which FIs should begin to align their reporting with such practices?
No
Source Reference Detail
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Source Reference Document
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P 2.47 – Does the Framework require/ask FIs to identify, measure, and report on exposure to sectors which are vulnerable to transition risk and physical risk?
No
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Source Reference Document
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P 2.48 – Does the Framework require/ask FIs to adopt and report on performance targets to reduce portfolio greenhouse gas (GHG) emissions on a regular basis?
No
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P 2.49 – Does the Framework require/ask FIs to adopt and report on performance targets to reduce exposure to climate change risks at the portfolio level on a regular basis?
No
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Source Reference Document
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Pillar 3 - Financing Sustainability - Strategic Alignment
National Framework
P 3.50 – Has the regulator or industry association published a national framework (“Framework”) for the banking sector that sets out expectations for integrating the consideration of instruments, goals, and standards for financing sustainability, including requirements for ensuring credibility and managing and measuring resulting impacts in the national economy?
No
Source Reference Detail
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Source Reference Document
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P 3.51 – Has the relevant regulator or industry association published a Framework for capital markets, investment, insurance or other non-lending FIs that sets out expectations for integrating the consideration of instruments, goals, and standards for financing sustainability, including requirements for ensuring credibility and managing and measuring resulting impacts in the national economy
No
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Source Reference Document
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Pillar 3 - Financing Sustainability - Strategic Alignment
Alignment with International Goals & Standards
P 3.52 – Has the regulator or industry association developed a strategy, regulations, or set of frameworks for stimulating the allocation of capital to sustainable assets, projects, and related sectors in line with global goals, such as the Sustainable Development Goals (SDGs)?
No
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P 3.53 – Does the Framework recognize and/or align with existing standards, voluntary principles, or market good practices related to sustainable finance instruments?
No
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Pillar 3 - Financing Sustainability - Regulatory and Industry Association Actions
Alignment with national goals & strategies
P 3.54 – Does the Framework enable the achievement of stated national objectives by guiding capital to sectors, assets, and projects that have environmental and social benefits in line with national sustainable development priorities, strategies, targets, and the size of sustainable investment needs, and taking into account the local barriers to scaling-up sustainable finance?
No
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P 3.55 – Does the Framework enable the achievement of stated national objectives by guiding capital to sectors, assets, and projects that have environmental and social benefits in line with national sustainable development priorities, strategies, targets, and the size of sustainable investment needs, and taking into account the local barriers to scaling-up sustainable finance?
No
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P 3.56 – Does any inter-agency data sharing currently exist related to stimulating and monitoring sustainable finance flows?
No
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Pillar 3 - Financing Sustainability - Strategic Alignment
Overall Approach & Strategy
P 3.57 – Does the Framework require/ask the regulator or industry association to establish mechanisms to identify and encourage the allocation of capital to sustainable sectors, assets, and projects?
No
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Pillar 3 - Financing Sustainability - Regulatory and Industry Association Actions
Technical Guidance
P 3.58 – Does the Framework require/ask the regulator or industry association to establish mechanisms to identify and encourage the allocation of capital to sustainable sectors, assets, and projects?
No
Source Reference Detail
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Source Reference Document
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P 3.59 – Does the Framework provide guidelines for extending green, social or sustainability-focused loans (excluding bonds)?
No
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Source Reference Document
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P 3.60 – Does the Framework provide guidelines for issuance of green, social or sustainability bonds?
No
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P 3.61 – Does the Framework require/ask for external party verification to ensure the credibility of sustainability instruments?
No
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Pillar 3 - Financing Sustainability - Regulatory and Industry Association Actions -
Supervisory activities & incentives
P 3.62 – Does the regulator or industry association monitor information reported by FIs related to green/social/sustainability investment, lending, and other instruments to prevent greenwashing and social-washing?
No
Source Reference Detail
–
Source Reference Document
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P 3.63 – Are there any financial or non-financial incentives for FIs to develop and grow green, social, or sustainability finance instruments?
No
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Source Reference Document
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Pillar 3 - Financing Sustainability - Regulatory and Industry Association Actions -
Tracking & Aggregated Disclosure
P 3.64 – Does the regulator or industry association collect and/or publish data from FIs or other sources about allocation of capital to green/social/sustainability assets, projects, or sectors?
No
Source Reference Detail
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Source Reference Document
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Pillar 3 - Financing Sustainability - Expectations of FI Actions
Strategy & Governance
P 3.65 – Does the Framework require/ask FIs to establish a strategy, governance, or high-level targets, including at the Board of Directors level, for capital allocation to sustainable assets, projects, or sectors?
No
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Source Reference Document
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Pillar 3 - Financing Sustainability - Expectations of FI Actions
Organizational Structure & Capacity Building
P 3.66 – Does the Framework require/ask FIs to define internal staff roles and responsibilities to encourage finance flows to green, social, and/or sustainability-focused investments?
No
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P 3.67 – Does the Framework require/ask FIs to develop and maintain internal staff capacity on green, social, or sustainability products through regular training and learning?
No
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Pillar 3 - Financing Sustainability - Expectations of FI Actions
Policies & Procedures
P 3.68 – Does the Framework require/ask FIs to put in place policies and procedures for defining, issuing, managing proceeds, tracking performance, and reporting on green, social or sustainability-focused products?
No
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Source Reference Document
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P 3.69 – Does the Framework require/ask FIs to appoint an independent external reviewer to confirm that the FI’s internal framework meets the requirements of the recognized national framework and regulations, or aligns to international standards?
No
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P 3.70 – Does the Framework require/ask that FIs create incentives for managers to increase sustainable loans or investments in the portfolio?
No
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Source Reference Document
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Pillar 3 - Financing Sustainability - Expectations of FI Actions
Tracking, reporting & disclosure
P 3.71 – Does the Framework require/ask FIs to publish annual updates on the performance and impacts of the sustainability instruments in compliance with relevant national and/or international standards?
No
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P 3.72 – Does the Framework require/ask FIs to obtain and disclose independent review of metrics reported annually in relation to the social and environmental outcomes and impacts achieved through the sustainability instruments?
No
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P 3.73 – Does the Framework require/ask FIs to obtain and disclose independent review of metrics reported annually in relation to the social and environmental outcomes and impacts achieved through the sustainability instruments?
No
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P 3.74 – Does the Framework require/ask FIs to report to the regulator(s) or industry association(s) on green, social, and/or sustainability bonds or other positive impact investments?
No
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P 3.75 – Does the Framework require/ask FIs to report publicly on their green, social and sustainability-focused finance activities and positive outcomes or impacts (i.e. not only to the regulator or shareholders)?
No
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