SBFN Member Since:

2013

Member Organisations

Central Bank of Nigeria

Progress Against sub Pillars

Framework Documents

RefCountryPolicies/ Principles/ GuidelinesYearIssuer
151Nigeria

Green Bonds Guidelines

2020Ministry of Environment
153Nigeria

Sustainability Disclosure Guidelines

2020Ministry of Environment
154Nigeria

New Rule on Green Bonds

2018Securities and Exchange Commission
155Nigeria

Reporting Template on Sustainable Financial Principles for the Capital Market

2019Securities and Exchange Commission
156Nigeria

Green Bond Financial Product listed

2018Securities and Exchange Commission
157Nigeria

Guidelines on Sustainable Financial Principles for the Capital Market

2019Securities and Exchange Commission
158Nigeria

Green Bond Issuance Rules

2018Securities and Exchange Commission
159Nigeria

Sustainable Finance Roadmap

2018Securities and Exchange Commission
160Nigeria

Reporting Template – Sustainable Banking Principles

2014Central Bank of Nigeria
161Nigeria

Sustainable Banking Principles Guidance Note and Sector Guidelines

2012Central Bank of Nigeria

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
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012) Reporting Template for the Nigerian Sustainable Banking Principles (CBN, 2014)
Source Reference Description

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?

Yes

Source Reference Detail
Source Reference Document
Nigeria Sustainable Finance Principles – National Roadmap (FSRCC, 2016)
Source Reference Description
Page 1

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
Commit to international standards and best practice initiatives: United Nations Global Compact, Millennium Development Goals, UNEP-FI, Global Reporting Inistiative financial sector supplement, World Business Council for Sustainable Development, Equator Principles
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 28 Principle 8

P 1.4 – Does the Framework make reference to established international ESG risk management standards and principles for FIs??

Yes

Source Reference Detail
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 5, Point 5

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
Principle 5 on Financial Inclusion refers to the Nigeria National Financial Inclusion Strategy.
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 28, Principle 5

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
Principle 8 page 28 (introductory framed text) & The NSBPs were developed in collaboration with Government Ministries and Agencies such as Federal Ministry of Environment. it is confirmed by the member in the 2019 report.
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 28, Principle 8

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

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
See Circular at the beginning of the Nigerian Sustainable Banking Principles Guidance Note and Sector Guideline. “The Central Bank of Nigeria (CBN) directs full adoption and implementation of these principles and guidelines by all banks discount houses and development finance institutions and will provide incentives, as necessary, to those institutions that take concrete measures to embed the provision of these principles and guidelines into their operational enterprise risk management and other governance frameworks”
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description

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?

No

Source Reference Detail
Source Reference Document
Source Reference Description

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
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description

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
Source Reference Document
Reporting Template for the Nigerian Sustainable Banking Principles (CBN, 2014)
Source Reference Description

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?

Yes

Source Reference Detail
See Circular at the beginning of the Nigerian Sustainable Banking Principles Guidance Note and Sector Guideline. “The Central Bank of Nigeria (CBN) directs full adoption and implementation of these principles and guidelines by all banks discount houses and development finance institutions and will provide incentives, as necessary, to those institutions that take concrete measures to embed the provision of these principles and guidelines into their operational enterprise risk management and other governance frameworks” Also, NIRSAL “seeks to create incentives and encourage the growth of formal credit to the entire agricultural value chain” Nigerian Sustainable Banking Principles Guidance Note and Sector Guideline pg 3
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 3

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
Source Reference Description

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
Page 5, Point 1 “Set the tone from the top” & Principle 6 page 25, 1st line of tab “Demonstrating progress”
Source Reference Document
Reporting Template for the Nigerian Sustainable Banking Principles (CBN, 2014)
Source Reference Description

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

Page 5, Point 1 “Set the tone from the top” & Principle 6 page 25, 1st line of tab “Demonstrating progress”

Source Reference Document

Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 5 – Point 1, Page 25 – Principle 6

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
Page 5, point 1 “Set the tone from the top” & Principle 6 page 25, 1st line of tab “Demonstrating progress” & Principle 7 page 26, point 1 “What does this Principle mean?”
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 5 – Point 1, Page 25 – Principle 6, Page 26 – Point 1

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
Principle 1, page 11 Point 1 “Provision of client engagement guidance on E&S issue”; Principle 7 page 26 point 6 ” Provide Sustainable Banking training sessions” and point 7 ” Create practical E&S training tools and resources”
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 11 – Principle 1, Page 26 – Principle 7, Point 1 and 7

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?

Yes

Source Reference Detail
Page 7, “Entities…should establish appropriate incentives to encourage and promote desired behaviours of employees to meet ESG standards.”
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 7

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
page 11, point 2; Principle 1 page 19,point 4 “Development of appropriate E&S policies” and point 5 “Development of appropriate E&S procedures”; Principle 1, page 9, (a),(b),(c),(g)
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 9 Principle 1 -(a),(b),(c),(g), Page 11 – Point 2, Page 19 – Principle 1, Point 4 and 5

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
Principle 1, page 11&12 4th line of tab Demonstratin Progress “E&S Management System reporting”
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 11 – 12, Principle 1

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
Principle 3, page 17 point 1 ” Integration of human rights due diligence into E&S procedures”
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 17 – Principle 3 Point 1

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
Principle 9, page 30 “Implementation of Principle 9” & Reporting Template for the Nigerian Sustainable Banking Principles (CBN, 2014)
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 30 – Principle 9

P 1.23 – Does the Framework require/ask FIs to report on ESG integration publicly?

Yes

Source Reference Detail
Page 5 states: “Bank shall articulate objectives, performance indicators and milestones against which the Bank can measure its progress in implementing the Principles and its Sustainable Banking policy and procedures. As part of its public commitment to adopting the Principles, a Bank will report publicly its implementation progress on an annual basis.”
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 5

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
Page 4 states: “The purpose of categorising the risk of a potential transaction is to guide Banks on the degree of E&S due diligence required to inform credit risk approval or underwriting decision-making and the appropriate level of E&S risk management and monitoring oversight that should be applied to the transaction.”
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 4

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
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012) and Reporting Template (2014) Principle 1 and definitions (Page 2, Pages 8-12) makes basic reference to climate risks as part of environmental risks and impacts including changes to the atmosphere resulting from GHG emissions (physical risk), and the 2014 Reporting Template for the Sustainable Banking Principles calls for reporting of amount of lending to companies or projects that have a high climate risk exposure in key sectors (Transportation, Banking, Chemicals, Utilities, Healthcare Management Services, Multi-line Insurance, non-renewable Energy) (Template for Principle 1, Item 1.12 page 4, or page 6 of PDF). The Power Sector Guidelines Appendix 1 (Page 45 of PDF, Page 8 of Appendix) references climate change legislation and related trade and financial impacts on sectors (e.g., oil sector activities and low carbon economy and reputational / transition risks) as related to oil and gas sector. Sector Guidelines for Oil and Gas (Page 64 of PDF, Section 3 of Guideline, Oil and Gas E&S Impacts: Climate Change Impacts) references transition to low emitting natural gas. Agriculture Sector Guidelines Table 1 Agriculture Value Chain and Potential E&S risks references climate mitigation and adaptation considerations in context of water supply and use. (Page 56 of PDF, page 6 of Guideline).
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012) Reporting Template for the Nigerian Sustainable Banking Principles (CBN, 2014)
Source Reference Description
(2) Page 2, 8 – 12 Page 45, 56, 64

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

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?

No

Source Reference Detail
Source Reference Document
Source Reference Description
P 2.28 – Does the Framework recognize or align with established regional or international good practice for climate risk management and disclosure by FIs?

No

Source Reference Detail
Source Reference Document
Source Reference Description

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? 

No

Source Reference Detail
Source Reference Document
Source Reference 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? 

No

Source Reference Detail
Source Reference Document
Source Reference 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

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
Source Reference Description

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
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012) for Oil and Gas, Agriculture, and Power Sector identify GHG sources and sinks and make basic reference to climate-related risks including water supply / drought, technology choices in conext of low carbon economy transition and reputational risk. The Power Sector Guidelines Appendix 1 (Page 45 of PDF, Page 8 of Appendix) references climate change legislation and related trade and financial impacts on sectors (e.g., oil sector activities and low carbon economy and reputational / transition risks) as related to oil and gas sector. Sector Guidelines for Oil and Gas (Page 64 of PDF, Section 3 of Guideline, Oil and Gas E&S Impacts: Climate Change Impacts) references transition to low emitting natural gas.
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 45

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
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012) and Agriculture Sector Guidelines Table 1 Agriculture Value Chain and Potential E&S risks references climate mitigation and adaptation considerations in context of water supply and use. (Page 56 of PDF, page 6 of Guideline), and importance of maintaining buodiversity and ecosystem services (which include services such as carbon sequestration).
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 56

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
Source Reference Document
Source Reference Description

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
Source Reference Description

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
Source Reference Document
Source Reference Description

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
Source Reference Document
Source Reference Description

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
Source Reference Document
Source Reference Description

P 2.40 – Has the regulator started to explicitly embed climate-related risk in supervisory activities and review processes as part of the Framework? 

Yes

Source Reference Detail
Page 4 requires annual reporting, and the Reporting Template requires reporting on lensing to climate exposed sectors.
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 4

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

Source Reference Detail
Source Reference Document
Source Reference Description

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
Source Reference Document
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
Source Reference Document
Source Reference Description

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
Source Reference Document
Source Reference Description

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
Source Reference Document
Source Reference Description

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
Source Reference Document
Source Reference Description

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?

Yes

Source Reference Detail
Calls for reporting of amount of lending to companies or projects that have a high climate risk exposure in key sectors (Transportation, Banking, Chemicals, Utilities, Healthcare Management Services, Multi-line Insurance, non-renewable Energy)
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 4 – Principle 1, item 1.12

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

Source Reference Detail
Source Reference Document
Source Reference Description

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

Source Reference Detail
Source Reference Document
Source Reference Description

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?

Yes

Source Reference Detail
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description

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

Yes

Source Reference Detail
Source Reference Document
Nigeria Green Bond Guidelines (Ministry of Environment, 2020) New Rule on Green Bonds (Securities Exchange Commission – SEC, 2018) Green Bond Financial Product listed (FMDQ OTC Securities Exchange, 2018) Nigerian Sustainable Finance Roadmap (FMDQ OTC Securities Exchange & UNEP FI, 2018) Sustainability Disclosure Guidelines (The Nigerian Stock Exchanges, 2018) Nigeria Sustainable Finance Principles – National Roadmap (Financial Services Regulation Coordinating Committee (FSRCC), 2016)
Source Reference Description

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)?

Yes

Source Reference Detail
Nigeria Green Bond Guidelines (Ministry of Environment, 2020) refers to UNFCCC and NDC
Source Reference Document
Green Bonds Guidelines, 2020
Source Reference Description
Page 1

P 3.53 – Does the Framework recognize and/or align with existing standards, voluntary principles, or market good practices related to sustainable finance instruments?

Yes

Source Reference Detail
Eligible Projects (5) – 2.3 Compliance with the GBP
Source Reference Document
Green Bond Financial Product listed (SEC, 2018)
Source Reference Description

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? 

Yes

Source Reference Detail

Nigeria Green Bond Guidelines (Ministry of Finance, 2020) mentions UNFCC and NDC, page 1

Source Reference Document
Green Bonds Guidelines, 2020
Source Reference Description

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?

Yes

Source Reference Detail
Principle 8 page 28 (introductory framed text) & The NSBPs were developed in collaboration with Government Ministries and Agencies such as Federal Ministry of Environment. The NSBPs were developed in collaboration with Government Ministries and Agencies such as Federal Ministry of Environment.
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 28 Principle 8

P 3.56 – Does any inter-agency data sharing currently exist related to stimulating and monitoring sustainable finance flows?

No

Source Reference Detail
Source Reference Document
Source Reference Description

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?

Yes

Source Reference Detail
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description

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? 

Yes

Source Reference Detail
Nigeria Green Bonds Rules (SEC, 2018), 2.0 & Nigeria Green Bond Financial Product listed (SEC, 2018), Eligible Projects
Source Reference Document
New Rule on Green Bonds (SEC, 2018) Green Bond Financial Product listed (SEC, 2018)
Source Reference Description

P 3.59 – Does the Framework provide guidelines for extending green, social or sustainability-focused loans (excluding bonds)?

No

Source Reference Detail
Source Reference Document
Source Reference Description

P 3.60 – Does the Framework provide guidelines for issuance of green, social or sustainability bonds?

Yes

Source Reference Detail
Source Reference Document
New Rule on Green Bonds (SEC, 2018) Green Bond Financial Product listed (SEC, 2018) Green Bond Principles & Green Bond Guidelines (Ministry of Environment, 2020)
Source Reference Description

P 3.61 – Does the Framework require/ask for external party verification to ensure the credibility of sustainability instruments?

Yes

Source Reference Detail
Source Reference Document
New Rule on Green Bonds (SEC, 2018)
Source Reference Description
Section 3.0 iv

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?

Yes

Source Reference Detail
Page 3, item 5.0 “…annual report and on its website or other media, a copy of which should be filed with SEC.”
Source Reference Document
New Rule on Green Bonds (SEC, 2018)
Source Reference Description
Page 3, item 5

P 3.63 – Are there any financial or non-financial incentives for FIs to develop and grow green, social, or sustainability finance instruments?

Yes

Source Reference Detail
Page 14 “Member agencies should incentivise their supervised entities that finance the priority sectors, which have the potential for accelerating the economic development of Nigeria. Such incentives may include guarantees, risk sharing measures, awards, and/or relaxed prudential requirements for finance granted to priority sectors of the economy.”
Source Reference Document
Nigeria Sustainable Finance Principles – National Roadmap (FSRCC, 2016)
Source Reference Description
Page 14

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?

Yes

Source Reference Detail
Page 3, item 5.0 “…annual report and on its website or other media, a copy of which should be filed with SEC.”
Source Reference Document
New Rule on Green Bonds (SEC, 2018)
Source Reference Description
Page 3, item 5

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?

Yes

Source Reference Detail
Page 4, “Implementation of the NSFP requires board and management commitment in formulating sustainable finance policies…”
Source Reference Document
Nigeria Sustainable Finance Principles – National Roadmap (FSRCC, 2016)
Source Reference Description
Page 4

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?

Yes

Source Reference Detail
Provide Sustainable Banking training sessions, Nigerian Sustainable Banking Principles Guidance Note and Sector Guideline pg 26
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 26

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?

Yes

Source Reference Detail
Provide Sustainable Banking training sessions, Nigerian Sustainable Banking Principles Guidance Note and Sector Guideline pg 26
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 26

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?

Yes

Source Reference Detail
Source Reference Document
Reporting Template for the Nigerian Sustainable Banking Principles (CBN, 2014)
Source Reference Description
1.13

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?

Yes

Source Reference Detail
Principle 6 page 25, §2, Principle 9 page 32 “Internal reporting system” and “External reporting”
Source Reference Document
Nigerian Sustainable Banking Principles Guidance Note and Sector Guidelines (CBN, 2012)
Source Reference Description
Page 25 – Principle 6 point 2, Page 32 – Principle 9

P 3.70 – Does the Framework require/ask that FIs create incentives for managers to increase sustainable loans or investments in the portfolio?

No

Source Reference Detail
Source Reference Document
Source Reference Description

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?

Yes

Source Reference Detail
Page 3, item 5.0 “…publish same in its annual report and on its website or other mediaannual report and on its website or other media…”
Source Reference Document
New Rule on Green Bonds (SEC, 2018)
Source Reference Description
Page 3, item 5

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?

Yes

Source Reference Detail
Page 20, “where appropriate, independent third party review and assurance of external reporting should be demonstrated”
Source Reference Document
Source Reference Description

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?

Yes

Source Reference Detail
Reporting Template for the Nigerian Sustainable Banking Principles (CBN, 2014), Question 1.14 Principle 1 (page 4)
Source Reference Document
Reporting Template for the Nigerian Sustainable Banking Principles (CBN, 2014)
Source Reference Description
Page 4 – Principle 1

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

Source Reference Detail
Source Reference Document
Source Reference Description

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)?

Yes

Source Reference Detail
The issuer shall publish an assessment report issued by an independent professional assessment or certification agency on its website or other media and conduct and report annual follow-up assessments of the green projects and associated environmental benefits throughout the tenor of the bond and publish same in its annual report and on its website or other media, a copy of which should be filed with SEC.
Source Reference Document
New Rule on Green Bonds (SEC, 2018)
Source Reference Description
Page 3