Central Bank Of Nigeria

Financial Policy & Regulation Department Central Business District P.M.B. 0187 Garki, Abuja.

Tel: +234-9462-37402. E-mail: fprd@cbn.gov.ng FPR/DIR/GEN/EXP/01/002 June 26, 2012

Exposure Draft Competency Framework For The Nigerian Banking Industry

In line with the on-going banking sector reforms and as part of efforts to promote, standardize and sustain skills and competency development in the Nigerian banking industry, the Central Bank of Nigeria (CBN), in collaboration with the Bankers' Committee, has developed and hereby issues the attached draft competency framework for stakeholder comments/inputs. The draft framework can be accessed at the CBN website www.cbn.gov.ng All responses in soft copies should be mailed to knamugo@cbn.gov.ng or mcakuka@cbn.gov.ng within two weeks from the date of this circular. However, where the response is in hard copy, this should be sent to the Director, Financial Policy & Regulation Department, Central Bank of Nigeria, Head Office, Abuja.

CHRIS O. CHUKWU
DIRECTOR, FINANCIAL POLICY & REGULATIONS DEPARTMENT June 12, 2012

1

CENTRAL BANK OF NIGERIA

DRAFT COMPETENCY FRAMEWORK FOR THE NIGERIAN BANKING INDUSTRY Banking Supervision Department/ Financial Policy & Regulation Department

Contents

1.0 Introduction 2.0 Objectives 3.0 Country Experiences 4.0 Banking Industry Job Families/Roles/ Controlled Functions 5.0 Approved Persons Database 6.0 Code of Practice for Approved Persons 7.0 Training and Certification 8.0 Accreditation of Training Service Providers 9.0 Role of the Other Relevant Stakeholders 10.0 Appendices

1.0 Introduction

The recent global financial crisis exposed the inadequacy of skills and dearth of executive capacity in the banking industry. The skill gap manifested in, among others:
The lack of in-depth knowledge of core banking functions and poor understanding of basic banking operations; Poor understanding of banking regulations; Poor risk management and corporate governance practices; Knowledge gaps in financial markets and treasury management; Knowledge gaps in business development practices; and Poor relationship management techniques.

Reasons advanced for these inadequacies include the lack of:
i. A coordinated industry-recognised training accreditation and certification system; and ii. Competency standards for practitioners in the industry.

From the foregoing, the development of staff competencies has become important in addressing these inadequacies, underscoring the need to train a new generation of banking professionals that is customer-centric, technologysavvy and flexible. With stability now restored to the Nigerian banking system following several measures and initiatives taken by the CBN under the on-going banking sector reforms, it is imperative that immediate steps be taken to consciously re-direct the banking industry towards the path of entrenching a sequenced competency development programme. The development of a competency framework for the Nigerian banking industry is predicated on the need for banks to accord high priority to the continuous enhancement of human capital and lifelong learning. This will imbue banking professionals with the requisite skills and expertise not only at the strategic and management levels, but also at the technical and operational levels. The availability of appropriately trained and competent human resources is a critical factor in supporting the effective performance of the banking industry. This, in essence, implies that continuous strengthening of intellectual resources and capabilities must be undertaken to create a pool of talented and high calibre professionals in the banking industry. The framework is expected to address the competency challenges in the banking industry, explore growth opportunities as well as critically facilitate improvement in the quality of the industry"s human capital. Under the framework, successful banks will be those that distinguish themselves by according high priority to continuous enhancement of human capital and lifelong learning. The proposed framework leverages on the practices in other jurisdictions such as Singapore, Hong Kong, Malaysia and Dubai which provide a useful guide and template for the Nigerian banking industry (See Appendix A for a review of country experiences).

2.0 Objectives Of The Framework

The objectives of the competency framework are to:
i. Define the minimum knowledge, skills and competencies needed for operators and regulators to perform optimally on their various jobs/tasks.

ii. To standardize capacity and competency development with a view to nurturing and producing a knowledgeable, skilled and competent workforce for the Nigerian banking industry iii. To establish standard competency requirements for each job role to serve as a guide to Nigerian banks for their talent recruitment and development programs iv. To provide standards for training certification, evaluation and accreditation to ensure the provision of quality training in the Nigerian banking industry v. To serve as a guide to practitioners to plan their careers and on the skills and competencies they need to stay employable and competitive vi. Serve as a tool for banks to assess their overall human capital capabilities; vii. Identify competency gaps and develop required learning interventions to bridge identified gaps.

viii. Provide a basis for sustaining career development in the Nigerian banking industry.

3.0 Banking Industry Job Families/Roles/Controlled Functions

In this framework, jobs in the banking industry have been classified into job families, roles and controlled functions. For each class of banking (commercial, merchant or specialised), there exists generic job families. These are occupational groups or clusters of closely-related jobs that capture the essence of an underlying business function; while job roles capture the essence of what must be done and how it should be done to achieve the required level of performance. On the other hand, controlled functions are roles within a business that have a particular operational and/or regulatory significance. A function may be designated as a controlled function if an individual exerts significant influence on the conduct of the financial institution"s affairs, in relation to controlled activities. Controlled functions are further classified into Significant Influence Functions and Customer Functions.

3.1 Significant Influence Functions

Significant influence functions are those functions that materially impact on the activities of the financial institutions. These can be divided into the following sub-groups:
i. Governing functions: These include entity significant influence roles such as Chairman, Managing Director, Deputy Managing Director, Executive Directors, Non-executive Directors, Independent Directors, ii. Regulatory functions: These include the Audit and Compliance functions.

iii. System and control functions: These include Finance, Risk, Internal Audit and Information Technology functions.

6 iv. Significant management functions: These include key management functions such as company secretariat, investment business, financial resources functions, Settlement and other key business operations functions.

v. Parent entity significant influence functions: This is applicable where a financial institution is a subsidiary and there are directors or employees of the parent company whose decisions or actions significantly impact the decisions of the board and management of the financial institution.

vi. Significant shareholders: These are investors with shareholding of 5%
or more in the financial institution.

3.2 Customer Functions

These are functions that can influence customers" decisions on investments and service adoption. They apply to advisers who communicate with the customers or deal with their assets. They include:
i. Specialized lending officers, ii. Ombudsman, iii. Branch managers, iv. Private banking adviser, and v. Customer service/contact centre managers vi. Retail advisory officers

Code	Function	Category
CFC0a	Significant parent entity functions
CFC0b	Significant shareholders
CFC1	Chairman of the Board	Significant
CFC2	Chairman of Board Risk Committee
CFC 3	Chairman of Audit committee	Influence
CFC 4	Chairman of Board Human Resource committee	Function
		7

Table 1: List of Controlled Functions

CFC 5	Chief Executive Officer/Managing Director
CFC 6	Deputy Managing Director
CFC 7	Executive Directors
CFC 8	Non-Executive Director
CFC 9	Chief Risk Officer,
CFC 10	Chief Financial Officer
CFC 11	Chief Internal Auditor
CFC 12	Chief Compliance Officer
CFC 13	Senior Credit Risk Officer
CFC 14	Senior Operational Risk Officer
CFC 15	Senior Market Risk/ALM Officer
CFC 16	IT Auditor
CFC 17	Chief Information Officer
CFC 18	Business Information Security Officer
CFC 19	Company Secretary
CFC 20	Treasurer
CFC 21	21	a.	Chief	Dealer/Financial	Markets	Officer
21.b. Dealers
CFC 22	Senior Corporate Finance Officer
CFC 23	Chief Economist /Senior Economist
CFC 24	Senior Lending Officer - Retail	Customer
CFC 25	Senior Lending Officer - Corporate	Function
CFC 26	Senior specialized Lending Officer
CFC 27	Senior Agricultural Lending Officer
CFC 28	Senior Operations Officer - Trade Finance	Significant Influence
CFC 29	Senior Operations Officer - Electronic Banking
CFC 30	Senior Operations Officer (General)	Function
CFC 31	Ombudsman
CFC 32	Customer Service/Contact Centre Manager
CFC 33	Private Banking Adviser	Customer
CFC 34	Branch Manager	Function
CFC 35	Retail Advisory Officer

Details of the banking industry job families\roles\functions and their minimum qualifications are provided in Appendix B.

4.0 Approved Persons Database

4.1 To ensure that only Fit and Proper persons man the different job roles and control functions within the banking industry, all persons for the position of Assistant General Manager and above as well as critical operational positions shall be approved for appointment in line with the Assessment Criteria for Approved Persons Regime issued and reviewed from time to time by the CBN.

4.2 In furtherance of this objective, a central database for approved persons shall be created and maintained at the CBN. All banks as reporting institutions shall update the database with details of approved persons and access it as part of their due diligence prior to the engagement and appointment of persons within the industry.

4.3 The Database Will:

i. Assign a unique identifier to each banking practitioner.

ii. Be accessed prior to the engagement or appointment of persons to board, top management or critical operational positions in the banking industry.

iii. Provide reference information to relevant stakeholders - regulators, employers, employees, auditors, business partners, etc - for the assessment of the continuous Fitness and Propriety of approved persons in the industry iv. Encourage transparency in the recruitment and appointment process.

4.4 Details in the database will include:
Full Names - surname, other names Commonly known names/alias names Identification number - National ID, International passport, drivers" licence number Controlled functions currently being performed The institution"s reference number History of previous approvals for the individual Disciplinary history Career history Credit points garnered from attendance and certification at accredited training programmes.

5.0 Code Of Practice For Approved Persons

5.1 An approved person, performing a controlled function, must act with integrity, due skill, care and diligence. He/she must observe proper standards of market conduct and deal with regulators in an open and cooperative way, disclosing any information of which regulators would reasonably expect to be notified.

5.2 An approved person performing a significant influence function must:
i. Take reasonable steps to ensure that the business of the financial institution for which he is responsible is organized so that it can be controlled effectively.

ii. Exercise due skill, care and diligence in managing the business of the financial institution for which he is responsible in his controlled function.

iii. Take reasonable steps to ensure that the business of the financial institution for which he is responsible complies with relevant laws, rules, guidelines and other regulatory requirements.

Details of the proposed code of practice for approved persons under this framework are provided in Appendix C.

6.0 Training And Certification

6.1 The framework seeks to ensure that persons engaged in the various job families/controlled functions have adequate skills and competencies to carry out the roles for which they have been certified.

6.2 There shall be structured generic and function or role-specific training and certification process that provides a reliable and objective assessment of an employee"s competence and ability to perform and meet the demands of a job consistently over time. Competencies and their related certifications will be based on job roles rather than job titles.

6.3 Training and certification will be provided by industry-recognized and/or accredited local and overseas training service providers. The minimum requirements for certification of each job role/control function are as indicated in Appendix B.
6.4 A training service provider could be any of the following:
An individual A profit-oriented consultancy outfit or commercial entity A not-for-profit entity The training/learning centres of banks Relevant professional bodies A university, polytechnic or other relevant educational institutions of higher learning.

6.5 Banks are expected to put in place policies that ensure quality and equitable training for all their staff. In this regard, training programmes attended by bank personnel over a period will be evaluated on the basis of total credit points obtained within a given period of time.

6.6 To attain and maintain competency in a particular job role, the individual responsible for a controlled function is expected to accumulate a minimum number of predetermined credit points, through attendance at and successful completion of accredited training programmes.

6.7 The credit points for training programmes attended shall be awarded by designated accreditation agencies, taking into cognisance such factors as: Duration and coverage of the programme, The faculty of the programme, Quality and relevance of the programme, The pedigree of the training provider.

6.8 To ensure objectivity and credibility in accumulating the required credit points, not more than 25 per cent shall be obtainable through an institution"s in-house training programmes.

6.9 The number of relevant accredited training attended and credit points accumulated shall be one of the assessment criteria in determining the suitability of approved persons for specific job roles/functions. Consequently, banks shall be required to populate the Approved Persons Database with details of credit points earned by approved persons in their employ.

7.0 Accreditation Of Training Service Providers

7.1 The accreditation of a training service provider will be conducted by an industry-recognized accreditation agency. The agency will carry out extensive review and evaluation in order to ascertain if the provider has the competence to conduct the training programme(s) envisaged under the Framework.

7.2 An agency shall be designated as an accreditation agency, subject to meeting the qualifying criteria to be prescribed by the Bankers" Committee and approved by the CBN from time to time.

7.3 An accreditation agency could be any of the following:
i. A recognized professional institute/body ii. A recognized educational institution of higher learning iii. A recognized training consultancy outfit iv. Other duly recognized body, institution or company.

7.4 The accreditation of training providers is a quality assurance mechanism to ensure that the training provider is qualified to provide the desired training and the programmes of the training provider meet the learning objectives and will impact the requisite knowledge, skills and competencies required for each job role.

7.5 The accreditation agency shall be responsible for accrediting training service providers. This will involve the endorsement of the training provider and its programmes based on an assessment of its curricula, competence, capacity, capability, faculty, resources, facilities, credibility, independence and integrity among other criteria, in carrying out specific training programme(s). The accreditation agency shall: Register training service providers Undertake an annual review of all training service providers and periodic review of their facilities for continuous quality assurance and relevance 7.6 There shall be two types of accreditation of training service providers, namely Solicited or Unsolicited.

7.7 Accreditation may not be solicited in respect of:
well established and/or industry-recognized training and certification programmes offered by qualified and eligible training service providers under this framework.

A training service provider duly accredited by a competent accreditation agency in Nigeria.

7.8 In every other case, training service providers wishing to offer their services in the Nigerian banking industry shall solicit and be duly accredited by a competent accreditation agency under this framework. Where accreditation is solicited, the cost of accreditation shall be borne by the service provider.

8.0 Role Of Stakeholders

The following stakeholders are expected to play various roles under the framework:

I. Central Bank Of Nigeria

The CBN will provide supervisory oversight, monitoring and regulatory guidance to ensure banks" compliance with the framework. In addition, the CBN will perform the following roles:
Coordinate the development of the Framework; Maintain the database of approved persons and financial institutions; Withdrawal of approvals where necessary; Application of sanctions for breaches by approved persons.

Ii. Nigeria Deposit Insurance Corporation

The Corporation will provide supervisory oversight in the implementation of the framework.

Iii. The Bankers' Committee

The Bankers" Committee would act as a coordinator alongside the CBN for the development and implementation of the framework.

Iv. Financial Institutions (Fis)

The financial institutions will provide specification of minimum competencies needed for each job role along with inputs for the specification of career paths, job descriptions and training curriculum needed for the development of the framework. Furthermore they are expected to:
Comply with data protection requirements.

Update the database with details of training programmes and credit units obtained by each officer performing a controlled function.

Periodically review the requirements of each controlled function.

Financial institutions are expected to continually satisfy themselves that the persons performing controlled functions have the necessary qualifications, experience, competence and capacity to carry out their duties.

V. Financial Institutions Training Centre (Fitc)

FITC is expected to provide inputs for the specification of competencies for job roles, career paths, job descriptions, and training curriculum. It will also act as a major training service provider and accreditation agency under the Framework.

Vi. Chartered Institute Of Bankers Of Nigeria (Cibn)

CIBN is expected to provide inputs for the specification of minimum competencies for job roles, career paths, job descriptions, and training curriculum. It will also issue ethical and professional guidance as wells as monitor the conduct of its members. It will also act as an accreditation agency and monitor the performance of the accredited training services providers.

Vii. Other Professional Bodies

These include professional bodies such as the Institute of Chartered Accountants of Nigeria (ICAN), Risk Management Association of Nigeria (RIMAN), Committee of Compliance Officers of Banks in Nigeria (COCOBIN), etc. They will also issue ethical and professional guidance and monitor the conduct of their members. They are also expected to develop training curricula and provide professional and other relevant training to their members and practitioners in the banking industry.

Viii. Accreditation Agencies

The accreditation agency will be responsible for registering and accrediting training service providers in the industry.

Ix. Training Service Providers

These are entities accredited to provide training services under the framework. These include professional bodies, educational institutions and other entities that are expected to design appropriate curricula oriented to the talent and skills needs of the Nigerian banking industry.

Country Experiences

To leverage international best practices and benefit from the experience of other countries, we reviewed the competency framework of the following jurisdictions:

A. Hong Kong

In 2008 Hong Kong established the Qualifications Framework (QF), which defined the standards for different qualifications. The framework was to help Hong Kong set clear goals and directions for continuous learning in order to obtain quality-assured qualifications. The QF applies to all sectors in the country; however, each industry (including the banking sub-sector) established an Industry Training Advisory Committee (ITAC) that developed the industry "specification of competency standards" (SCSs). Upon the acceptance of the SCSs by the industry, accredited training providers developed appropriate training programmes. The QF was designed to enhance the overall quality and competitiveness of the local workforce. The QF is set up as a hierarchy of qualifications encompassing seven levels. Each level is characterized by outcome-based generic descriptors, which describe the common features of qualifications at the same level. The generic level descriptors describe the requirements of each level in four aspects: "knowledge and Intellectual Skills", "Processes", "Application, Autonomy and Accountability" and "Communications, IT and Numeracy". The training programmes developed by training providers are only recognised under the QF if they are quality-assured by the Hong Kong Council for Accreditation of Academic and Vocational Qualifications. The Hong Kong Government subsidises QF programmes through the Qualifications Framework Support Scheme (QFSS), which was launched to assist and encourage educational and training providers in seeking accreditation of their programmes as well as registration of the programmes in the Qualifications Register. QFSS are time-bound and nonrecurrent financial assistance schemes approved by the Finance Committee of the Legislative Council.

B. Singapore

The Financial Industry Competency Standards (FICS) Framework, a comprehensive quality assurance framework with a certification and accreditation system that aims at raising the quality of the financial workforce and training providers, was set up in Singapore. The FICS comprises a set of standards with associated curriculum guide that relates to the competencies required for practitioners in specific job roles. The FICS framework encompasses job families across all functional and business areas, including Compliance, Corporate Banking, Corporate Finance, Financial Markets, Fund Management, General Insurance, Life Insurance, Private Equity, Risk Management, Securities & Futures and Wealth Management. The Framework covers the whole of Singapore"s financial system - banking, insurance, pension, and the capital market.

The FICS was developed by the industry, for the industry with the support of leading financial institutions and industry associations, the Monetary Authority of Singapore and the Singapore Workforce Development Agency. It is aligned with the structure and requirements of the Singapore Workforce Skills Qualifications (WSQ) system and recognised as the basis for WSQ awards for the financial services industry. Generally, the Singapore Financial Sector Development Fund refunds 70% of the cost of training and assessment. The Institute of Banking and Finance (IBF), which developed the Framework, is the national accreditation and certification agency for financial competency under the FICS. The FICS certification is an industryendorsed quality mark that distinguishes a certified practitioner from others in the same occupation. Apart from recognising a practitioner's professional competence and capacity to undertake a specific occupation, the certification also signifies the practitioner's commitment to adhere to the relevant code of ethics and rules of professional conduct. The IBF maintains a database of all certified practitioners in the Singaporean financial system.

C. Dubai

The Dubai Model was aimed at evolving strategies for developing human capital for the financial sector. A two-layered approach was adopted for developing human capital in the financial services industry, on the one hand, and the educational system, on the other. Strategies for developing human capital for the financial services industry included:
Establishment of the Human Resources Development Award to encourage banks to invest in human capital development Implementation of an "Emiratisation" policy to give preference to the citizens of the emirates working in financial institutions Establishment of an inter-agency committee to identify and address skill gaps in financial institutions Setting up of an Office of Financial Education to stimulate mass financial education Strategies to enhance the development of the educational system included:
Establishment of a body to match the real needs of employers to qualifications of UAE nationals seeking employment by aligning the educational curricula to provide skills required by employers Placing emphasis on vocational education to boost human capital development through the establishment of vocational centres by government.

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
1	Significant	Governing	Chairman of	To ensure effective	* good understanding	*General	leadership	A first degree or its	Relevant experience in
Influence	Function	the Board	operation of the Board	of	the	role	of	a	Skills/Influencing skills	equivalent	in	any	business/executive
Functions	such that it works	Chairman and able to	*Team	building	/	discipline	role
towards achieving the	operate effectively in	conflict	management
company's	strategic	such a role at the	*Organization	and	Membership	of	15	years	post
objectives	highest level. Relevant	coordination	skills	Institute of Directors or	graduation experience.
financial	industry	*People	Skills	any other relevant and
experience	is	*Initiative	recognised	5	years	board
desirable.	*Entrepreneurship/	professional institute	experience	in
* good understanding	taking	ownership	Financial	Services
and	experience	of	*Analytical	Skills/	Industry
Nigerian	boardroom	Problem	solving
and	corporate	*Self
governance issues.	Management/Interpers onal Skills
2	Significant	Governing	Chairman of	* presides at meetings	Good understanding of	*General	leadership	A first degree or its	12	years	post
Influence	Function	Board	Risk	of the Board Risk	risk issues in financial	Skills/Influencing skills	equivalent	in	any	graduation experience.
Functions	Committee	Committee and ensure	services.	*Team	building	/	discipline.	5 years experience in
that the work of the	Financial acumen	-	conflict	management	risk management
Committee	is	Must be comfortable	*Organization	and	Membership	of
performed	in	an	dealing	with	risk	coordination	skills	Institute of Directors or
efficient	and	timely	issues	and	make	*People	Skills	any other relevant and
manner.	every effort to keep up	*Initiative	recognised
to	date	with	best	*Entrepreneurship/	professional institute
* Ensures that the	practice developments	taking	ownership
Committee	provides	in risk management	*Analytical	Skills/
oversight and advice	and measurement	Problem	solving
to	the	Board	on	*Self
current risk exposures	Management/Interpers

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
and future risk strategy	onal	Skills
3	Significant	Governing	Chairman of	* presides at meetings	*	Knowledge	and	*General	leadership	A first degree or its	5 years experience in
Influence	Function	Audit	of	the	Audit	understanding of audit	Skills/Influencing skills	equivalent	in	any	Accounting or Audit
Functions	committee	Committee and ensure	issues,	*Team	building	/	discipline.	role
that the work of the	* Good knowledge of	conflict	management	12	years	post
Committee	is	banking operations	*Organization	and	Membership	of	graduation experience.
performed	in	an	coordination	skills	Institute of Directors
efficient	and	timely	*People	Skills
manner.	*Initiative *Entrepreneurship/
Ensures	that	the	taking	ownership
Committee effectively	*Analytical	Skills/
reviews	the	Problem	solving
appropriateness	and	*Self
completeness of the	Management/Interpers
company's system of	onal	Skills
internal	control,
reviews	the	report
which identifies high level control issues of Group Level significance that require or are subject to remedial action and ensures that the Committee considers whether necessary actions are being taken to remedy any	24

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
significant failings or weaknesses. The chairman presides at meetings of the Committee and ensure that the work of the Committee is performed in an efficient and timely manner.
4	Significant	Governing	Chairman of	To lead the Human	* knowledgeable about	*General	leadership	A first degree or its	12	years	post
Influence	Function	Board Human	resource	Committee	current best practice in	Skills/Influencing skills	equivalent	in	any	qualification
Functions	Resource	in	developing	and	HR	policies	and	*Team	building	/	discipline.	experience.
committee	implementing	human	executive recruitment	conflict	management	5 years experience in
resource	and	* knowledgeable about	*Organization	and	Membership	of	Human	Capital
remuneration policies	current best practice in	coordination	skills	Institute of Directors	Management
and	practices	that	executive	*People	Skills
support the delivery of	remuneration	and	*Initiative
the business strategy	understand	the	*Entrepreneurship/
and	which	thereby	importance of aligning	taking	ownership
help create value for	executive reward to	*Analytical	Skills/
shareholders.	the achievement of the	Problem	solving
Group's	strategic	*Self
objectives.	Management/Interpers onal Skills

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
5	Significant	Governing	Chief	Responsible for the	*Knowledge	and	*General managerial/	A first degree or its	Minimum of 15 years
Influence	Function	Executive	conduct of the whole	understanding of the	administration	equivalent	in	any	post	graduation
Functions	Officer/Manag	of the business of the	Nigerian	banking	*Team	building	/	discipline.	experience	with	at
ing Director	company under the	market.	conflict	management	least 10 years in the
immediate authority of	*Strong	strategic	*Coaching	/	Relevant	higher	Banking	Sector.
the	Board.	orientation	Leadership	/	degrees	and
*Excellent	customer	Influencing	professional	A minimum of 8 years
To develop strategies	relationship	*Organization	and	certifications	must have been spent
that enable the bank to	development/manage	coordination	skills	e,g ACIB	at senior management
achieve its corporate	ment	*People	Skills	level with responsibility
objectives and to co	*Good	negotiation,	*Initiative	for	Business
ordinate,	direct	&	problem-solving	and	*Entrepreneurship/	development	,
control current to long	conflict	resolution	taking	ownership	Customer relationship
term development of	*Creative	and	*Analytical	Skills/	Management	or
market	penetration	innovative	Problem	solving	Customer	Service
strategies	while	*Knowledge	and	*Self	management
meeting	and	understanding	of	Management/Interpers
exceeding customer's	commercial	financial	onal	Skills
requirement as well as	products	*Advanced	Credit
maximizing profit and	*Good	product	Skills
minimizing cost and	development	and
risk.	portfolio management capabilities
To carry out the day	*Visibility of	market
to-day running of the	relevance	&
company; guiding the	networking	ability
development	and	* Knowledge of risk
growth of the company	management
and	acting as the
company's	leading	26

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
representative in its dealings with its stakeholders.
6	Significant	Governing	Deputy	Responsible for the	*Knowledge	and	*General managerial/	A first degree or its	Minimum of 15 years
Influence	Function	Managing	conduct of significant	understanding of the	administration	equivalent	in	any	post	graduation
Functions	Director	aspect of the business	Nigerian	banking	*Team	building	/	discipline.	experience	with	at
of the company under	market	conflict	management	Relevant	higher	least 10 years in the
the supervision of the	*Strong	strategic	*Coaching	/	degree	and	Banking	Sector
CEO. In the absence	orientation	Leadership	/	professional
of the CEO, he takes	*Excellent	customer	Influencing	certifications	A minimum of 8 years
responsibility for CEO	relationship	*Organization	and	e,g ACIB and others	must have been spent
roles with	approved	development/manage	coordination	skills	at senior management
delegated	authority.	ment	*People	Skills	level with responsibility
*Good	negotiation,	*Initiative	for	business
problem-solving	and	*Entrepreneurship/	development	and
To	dev	conflict	resolution	taking	ownership	customer relationship
*Creative	and	*Analytical	Skills/	management
innovative	Problem	solving
*Knowledge	and	*Self
understanding	of	Management/Interpers
commercial	financial	onal	Skills
products	*Advanced	Credit
*Good	product	Skills
development	and
portfolio management capabilities *Visibility of market relevance & networking ability

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
7	Significant	Governing	Executive	Responsible	for	*Knowledge	and	*General managerial/	A first degree or its	Minimum of 15 years
Influence	Function	Directors	making	and	understanding of the	administration	equivalent	in	any	post	qualification
Functions	implementing	Nigerian	banking	*Team	building	/	discipline.	experience	at least
operational decisions	market.	conflict	management	Relevant	post	10years	in	the
and	running	the	*	knowledgeable	in	*Coaching	/	graduate/professional	Banking	Sector.	A
Group's business on a	relevant areas of the	Leadership	/	certifications	minimum of 8 years
day-to-day basis under	company's activities in	Influencing	e,g ACIB and others	must have been spent
the leadership of the	additon	to	*Organization	and	at senior management
Chief	Executive	qualifications that may	coordination	skills	level
be required for their	*People	Skills
The	duties	of	an	specific	assignments	*Initiative
executive	Director	or	responsibilites.	*Entrepreneurship/
include the general	*Strong	strategic	taking	ownership
duties applicable to all	orientation	*Analytical	Skills/
Directors	These	*Excellent	customer	Problem	solving
duties extend to the	relationship	*Self
whole of the business	development/manage	Management/Interpers
and not just that part	ment	onal	Skills
of it covered by their	*Good	negotiation,	*Advanced	Credit
individual	executive	problem-solving	and	Skills
responsibilities.	conflict	resolution
*Creative	and
innovative *Knowledge	and
understanding	of
commercial	financial
products *Good	product
development	and
portfolio management 28
---	---	---	---	---	---	---	---	---	---	---	---
Type	Skills	and
	Competencies capabilities *Visibility of	market
	relevance	&
	networking ability
8	Significant	Governing	Non	*	constructively	* broad experience,	*General managerial/	A first degree or its	Minimum of 12 years
Influence	Function	Executive	challenge	and	integrity and credibility.	administration	equivalent	in	any	post	graduation
Functions	Director	contribute	to	the	*Proven	skills	and	*Team	building	/	discipline.
development	of	competencies in their	conflict	management
strategy.	fields;	*Coaching	/	Membership	of
*	scrutinise	the	*Knowledge	of	the	Leadership	/	Institute of Directors
performance	of	operations	of	Influencing
management	in	banks/discount houses	*Organization	and
meeting agreed goals	and relevant laws and	coordination	skills
and	objectives	and	regulations guiding the	*People	Skills
monitoring, and where	financial	services	*Initiative
necessary	removing,	industry;	*Entrepreneurship/
senior	management	*Ability	to	make	taking	ownership
and	in	succession	meaningful	*Analytical	Skills/
planning	contributions to board	Problem	solving
* satisfy themselves	deliberations;	*Self
that	financial	Management/Interpers
information is accurate	onal Skills
and	that	financial
controls and systems of risk management are robust and defensible. * determining appropriate levels of remuneration of	29

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
executive	directors
and have a prime role in appointing, and where necessary removing, senior management and in succession planning. * bring independent judgment as well as necessary scrutiny to the proposals and actions of the Management and executive directors especially on issues of strategy, resources, performance evaluation and key appointments and standards of conduct.
9	Significant	Regulatory	Chief	To	implement	* Banking Operations (	*	Excellent	* A first degree or its	Minimum of 8 years
Influence	Required	Compliance	measures that would	Domestic	&	interpersonal	skills,	equivalent	in	any	post	qualification
Functions	Function	Officer	ensure the adherence	International	with the confidence to	discipline.	experience in	Risk/
to	appropriate	Operations)	approach people at all	*	Recognised	Control	functions
compliance framework	*	Accounting	levels	of	seniority	professional	within the Financial
and procedures so as	* Credit Analysis /	*	An	enquiring	certification such as	Services Industry
to minimize loss from	Appraisal	analytical	mindset	CFA,	CIS,	ACCA,
non-compliance	with	*	Environmental	/	*	Methodical	and	ACA,	CFP,	CFE,
the	policies	&	Industry	Analysis	systematic	in	work	ACAMS,	IT
procedures	* Risk Management	approach	Certifications, etc
	30
---	---	---	---	---	---	---	---	---	---	---	---	---
Type	Skills	and
Competencies * Operational	risk	*	Excellent	report
Responsible	for	* Investment / Portfolio	writing	skills
ensuring the rules and	Management	* Articulate, confident
principles set by the	* Assets & Liabilities	communicator	and
CBN	and	other	Management	presenter
regulators are being	* Financial analysis /	*	Assertive	and
adhered to, under the	interpretation	persuasive	§	Self
guidance	of	the	*	TQM	motivated with good
organisation's	senior	* Documentation	teamwork	skills	*
management	team	Attention	to	detail
and the Board.	* Knowledge of the legal and regulatory framework and the regulatory environment
10	Significant	Significant	Company	To	manage	the	*	Knowledge	and	*Strategic	Focus/	A first degree
Influence	Manageme	Secretary	company	secretariat	understanding	of	Orientation	Professional	post	graduation
Functions	nt Function	and	ensure	banking	operations	*Integrity	and	Certifications -	ACA,	experience within the
compliance	with	(international	&	Discretion	ACCA,	or	ACS	Financial	Services
Bank's	rule	and	domestic)	*Initiative/	Proactive	Industry with at least
regulation and prevent	*	Legal	financial	*Entrepreneurship	Degree in Law and BL	4	years	at	senior
reputational	risk	planning	*Analytical	skills	/	for those acting as	management level
among	the	Bank's	*	Good	policy	Problem	solving	Legal Advisers.
stakeholders	development	and	*Resilience,	Tenacity
management	and	Integrity
To	Provide	legal	capabilities	*Interpersonal	skills
counsel and support to	* Legal documentation	*Communication (oral
the Bank as it relates	*	Legal	Advice	&	written)
to contracts, litigation	*	Litigation	*General managerial/
and dispute resolution,	*	Regulatory	administration
31
---	---	---	---	---	---	---	---	---	---	---	---	---
Type	Skills	and
Competencies
credit and employment	Knowledge	*Leadership/influencin
issues.	*	Corporate	g
Governance		*Organization	and
*	Compliance	coordination	skills
Monitoring		*Coaching and people
*	Banking	Industry	management
Knowledge		*Conflict management
* Financial Industry Knowledge * Knowledge and understanding of Financial Regulations (Domestic & International) * Knowledge and understanding of Risk Management and Financial Standards (Domestic & International)
11	Significant	Significant	Treasurer	To effectively manage	- Excellent numerate	-	Initiative	A first degree in any	Minimum of 15 years
Influence	Manageme	the liquidity of the	skills	-	Entrepreneurship/	discipline	and	post	graduation
Functions	nt Function	Bank in a bid to	-	Knowledge	and	taking	ownership	Relevant professional	experience	out	of
actualize	the	understanding of the	-	Analytical	Skills/	certifications e.g ACI,	which 10 years must
objectives of the Bank	local	and	global	Problem	solving	or Treasury Dealership	have been spent in
while complying with	financial	markets	- Self-Management	Certificate	treasury	related
all	regulatory	- Excellent customer	function.
requirements.	relationship
-	Develop	and	development/
implement all policies	management 32

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
as they relate to the	- Good negotiation and
Treasury	function	social	skills
-	Co-ordinate	the	-	Creative	and
Assets and Liability	innovative
Committee of the Bank	-	Knowledge	and
- Ensure compliance	understanding of the
with regulatory and	Banks'	products
internal	ratios	and	- Good knowledge of
limits as they relate to	product development
all Treasury products	-	Excellent
and	the	Bank's	relationships with the
balance	sheet.	regulatory authorities
- Oversee the trading desks in the development and implementation of strategies and products to meet the Bank's trading budgets.(FX, Securities, etc..)

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
12	Significant	Significant	Chief	§ Monitoring market	§ Broad knowledge	Articulate,	clear	A first degree and	Minimum of 12 years
Influence	Manageme	Dealer/Financ	performance	about securities and	communicator	relevant	professional	post	qualification
Functions	nt Function	ial	Markets	§ Monitoring incoming	equities markets and	§ Strong client service	certifications such as	experience	out	of
officer	electronic	trade	services, with detailed	ethic	ACI	or	Treasury	which 8 years have
instructions	knowledge relating to	§ Excellent IT and	Dealership Certificate.	been spent in treasury
§	Processing	or	the specific area you	numeracy	skills	related	function.
Dealers	executing trades as	are	trading	in	§ Driven to work in a
per client instructions,	§ Specialist knowledge	team setting	Minimum of two years
either by telephone or	relating	to	specific	treasury	experience
online	securities	products,	for dealers.
§ Analysing research	such as derivatives,
compiled	by	bonds and funds, and
investment analysts to	secondary	trading
identify	market	markets
opportunities	- Quick thinking and
§	Advising	fund	/	ability	to	perform
investment managers	under	pressure
and stockbrokers on	§	Accurate	and
significant changes in	excellent attention to
market	and	detail
recommending buy /	§ Swift reactions to
sell	actions	changing	market
§ Deciding on the	conditions
products to buy and	§	Good	analytical
sell,	using	careful	skills, with the ability to
judgement	and	digest and summarise
research to try and	multiple	sources	of
predict	how	the	information
markets are likely to	§	Accountable	for
move	actions and decisions 34

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
§	Purchasing	new	§ Resilient and ability
share	issues	to operate in a lively,
§ Preparing reports to	fast-paced
summarise	trading	environment
activities	§	Self-confident
§ Ensuring details of	§ Discrete and ethical
any	problems	or	§	Well-organised
delays in processing	§	Outstanding
instructions	are	business
reported promptly to	communication	and
the relevant authority	interpersonal	skills
§ Regularly monitoring	§
global economic and political developments that can affect prices § Constantly networking to maintain strong relationships with analysts, investment managers and brokers § Compliance with legal requirements, industry regulations, organisational policies and professional code

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
	Competencies
13	Significant	Significant	Senior	*To provide innovative	*	Strong	business	*Leadership	/	* A first	degree in	Minimum of 10 years
Influence	Manageme	Corporate	financial solutions to	origination and deal	Supervisory	relevant	discipline.	experience in a bank
Functions	nt Function	Finance	the bank's corporate	execution	skills.	*Team	building	/	*	Relevant	or	other	financial
Officer	clients	including	*	Excellent	product	conflict	management	professional	institution , with	a
medium to long term	management	*Organization	&	certifications	in	minimum of 5 years in
financing solutions	*Excellent	customer	coordination	Accounting,	Banking	Corporate	Finance
	relationship	*General managerial /	or Finance e.g CFA	function
	development/manage	administration
	ment	*Interpersonal	skills
	*Financial	Markets	*Computer
	Knowledge	appreciation	/	data
	*Fin.	entry	(word
	Analysis./Business	processing/spreadshe
	accountability	et/graphics)
	*Results/Action	*Communication (oral
	Orientation	& written)
	*Presentation	Skills
	*Ability	to	manage
	multiple	tasks
	*Superior	product
	knowledge *Fin. Planning/Budgeting & Forecasting

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
14	Significant	Significant	Chief	Advise	Management	* Quantitative analysis	*	Strategic	Focus/	Masters	degree	in	Minimum of 10 years
Influence	Manageme	Economist or	on economic issues.	and	modelling	Orientation	Economics or related	post	qualification
Functions	nt Function	Senior	Forecast	economic	* Sound and detailed	*	Integrity	and	discipline.	relevant	experience
Economist	and financial indicators	knowledge of trading	Discretion	with at least 5 years at
and provide outlook/	dynamics, quantitative	* Initiative/ Proactive	a senior management
recommendation	valuation and Treasury	*	Entrepreneurship	level
operations	* Analytical skills /
* Deep knowledge of	Problem	solving
the Bank's trading and	* Resilience, Tenacity
treasury	products	and	Integrity
* Sound knowledge of	* Interpersonal skills
asset	and	liability	* Communication (oral
management	&	written)
* Deep understanding	*	Leadership
of the structure and	*	Coaching
complexities	of	/Leadership	/
market cycles (Local	Influencing
and	Foreign)	*
* Ability to analyse and	Initiative/Entrepreneur
interpret market and	ship/ taking ownership
economic	*	Team	building	/
information/data	conflict	management
* Detailed knowledge	*	Organization	&
of regulatory policies	coordination
and objectives	* General managerial /administration

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
15	Significant	Significant	Senior	To manage the banks	*Excellent	customer	*Leadership	/	A first degree in any	Minimum of 10 years
Influence	Manageme	Lending	overall Retail Business	relationship	Influencing	discipline.	Relevant	relevant	experience
Functions	nt Function	Officer	-	within	the	target	development/manage	*Team	building	/	professional	with at least 5 years
Retail	markets and to give	ment	conflict	management	certifications	in	in a management role
overall direction and	*Strong	strategic	*Organization	&	Banking	such as	in Retail Banking.
supervision	of	the	Orientation	coordination	ACIB or others
Division's strategies	*Advance selling skills	*General managerial /
*Knowledge	and	administration
understanding	of	*Interpersonal	skills
Nigerian Retail market	*Computer
*Basic	Banking	appreciation	/	data
Operations (Domestic	entry	(word
&	International	processing/spreadshe
Operations)	et/graphics)
*Products Knowledge	*TQM
*Environmental	/
Industry	analysis
*Documentation
16	Significant	Significant	Senior	To	coordinate	the	*	Good	Banking	*	Good	customer	A first degree in any	Minimum of 10 years
Influence	Manageme	Operations	execution	of	Operations (Domestic	service / Relationship	discipline.	Relevant	relevant experience , 5
Functions	nt Function	Officer	-	International trade and	&	International	management	skills	professional	years	must	be	in
Trade	Payments transactions	Operations)	*	Team	building	/	certifications such as	foregin operations and
Finance	in efficient and cost	*	Good	accounting	Conflict management	ACIB,	at least 5 years in
effective manner inline	knowledge	* Interpersonal skills	management role.
with	bank's	overall	* Products knowledge	* Communication (oral
strategy .To provide	* Excellent negotiation	&	written)
efficient	foreign	skills	* General managerial/
banking services to	*	Good	financial	administration
customers	analysis	/	*	Leadership	/
Interpretation	skills	Influencing
	38

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies * Documentation skills	*	Organization	and
* Good knowledge and	coordination	skills
understanding of UCR	*	Performance
*	Needs	to	have	management
contacts	with	* Coaching
regulators and major international financial institutions
17	Significant	Significant	Senior	Develop	and	* Good knowledge &	* Strategic orientation	A first degree in any	Minimum of 10 years
Influence	Manageme	Operations	implement a business	understanding	of	* Creative and taking	discipline.	Relevant	relevant	experience
Functions	nt Function	Officer	unit plan that facilitates	banking operations (	initiative	professional	with at least 5 years at
(General)	the delivery of quality	Domestic	&	*	Entrepreneurship/	certifications such as	senior	management
products and excellent	International	taking	ownership	ACIB,	level. Experience in
customer	service	Operations)	*	Analytical	Skills/	banking	operations
delivery	across	the	*	Good	products	Problem	solving	and customer services
bank's branch network	knowledge	*	Self-Management
,	including	cash	*	Process	* Interpersonal Skills
centres and Implant	management	and	* General managerial/
service .Develop and	documentation	skills	administration
sustain a customer	* Good communication	*	Team	building	/
focused	service	skills (oral & written)	conflict	management
delivery organisation	*	Leadership/
	Coaching/ Influencing/ Supervisory * Organization/ Coordination skills * Performance management

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
18	Significant	Significant	Branch	To	establish	and	> Good understanding	*Integrity	and	A first degree in any	A minimum of 8 years
Influence	Manageme	Manager	maintain	positive	of	policies	and	Discretion	discipline.	Relevant	banking	experience
Functions	nt Function	customer	procedures,	*Initiative/	Proactive	professional	with at least 2 years in
relationships, plan and	Core	Business	*Analytical	skills	/	certifications such as	branch operations or
deliver	an	effective	Processes,	Industry	Problem	solving	ACIB	retail banking.
marketing and service	knowledge, audit and	*Resilience,	Tenacity
strategy and monitor	fiscal	analysis,	and	Integrity
the progress of new	Banking	Operations	*Interpersonal	skills
and existing products;	Banking	*Communication (oral
as well as provide	services/products,	&	written)
operational	Use	of	Banking	*General managerial/
management support	applications,	administration
on a day-to-day basis.	Accounting,	Credit	*Leadership/influencin
May be responsible for	Analysis	g
a whole branch or a	*Organization	and
number of branches.	Excellent	people,	coordination	skills
leadership, motivation	*Coaching and people
and	communication	management
skills	including	the	*Conflict management
ability	to	engage,
inspire and influence others * Strong, innovative customer service ethic * Professional and credible * Flexible, able to juggle and delegate workloads * Calm and confident 40

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies in handling potential conflict situations * Understanding of financial product regulations and the legal aspects of banking * Comfortable working in an environment where adherence and quality control are essential * Business focused, with good all-round knowledge of marketing, sales, training and people management
19	Significant	Significant	Senior	To manage the banks	*Excellent	customer	*Leadership	/	A first degree in any	Minimum of 10 years
Influence	Manageme	specialized	overall	relationship	Influencing	discipline.	Relevant	experience in a bank
Functions	nt Function	Lending	development/manage	*Team	building	/	professional	with at least 3 years
Officer	ment	conflict	management	certifications such as	experience	in	a
*Strong	strategic	*Organization	&	ACIB,	management role.
Orientation	coordination
*Advance selling skills	*General managerial /
*Knowledge	and	administration
understanding	of	*Interpersonal	skills
Nigerian Retail market	*Computer
*Basic	Banking	appreciation	/	data
Operations (Domestic	entry	(word
41

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies & International	processing/spreadshe
Operations)	et/graphics)
*Products Knowledge	*TQM
*Environmental	/
Industry	analysis
*Documentation
20	Significant	Significant	Senior	To manage the banks	*Excellent	customer	*Leadership	/	A first degree in any	Minimum of 10 years
Influence	Manageme	Agricultural	Agricultural	lending	relationship	Influencing	discipline.	Relevant	experience in a bank
Functions	nt Function	Lending	portfolio	and	development/manage	*Team	building	/	professional	with at least 3 years
Officer	relationships	and	ment	conflict	management	certifications such as	experience	in	a
ensure aderence to all	*Strong	strategic	*Organization	&	ACIB,	management role.
related requirements.	Orientation	coordination
*Advance selling skills	*General managerial /
*Knowledge	and	administration
understanding	of	*Interpersonal	skills
Nigerian Retail market	*Computer
*Basic	Banking	appreciation	/	data
Operations (Domestic	entry	(word
&	International	processing/spreadshe
Operations)	et/graphics)
*Products Knowledge	*TQM
*Environmental	/
Industry	analysis
*Documentation

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
21	Significant	System	&	Chief	Risk	To	monitor	and	*	Knowledge	and	*	Strategic	Focus/	* A first degree in any	Minimum of 15 years
Influence	control	Officer,	coordinate the overall	understanding	of	Orientation	discipline	post	qualification
Functions	Function	risk	management	Banking	Operations	*	Integrity	and	*	Recognized	experience in	risk
function.	(International	and	Discretion	professional	management or relaed
domestic)	* Initiative/ Proactive	certification such as	area	within	the
* Strategic orientation.	*	Entrepreneurship	CFA,	CIS,	ACCA,	Financial	Services
Creativity & innovation	* Analytical skills /	ACA, CFP,	etc.	Industry , of which at
*	Good	policy	Problem	solving	GARP, PRMIA	least 10 must have
development	and	* Resilience, Tenacity	been in the Banking
management	and	Integrity	Sector and	10years
capabilities	* Interpersonal skills	must have been at a
* Financial Acumen	* Communication (oral	senior	management
*	Finance	&	&	written)	level.
Accounting	* General managerial
*	Banking	Industry	/administration
Knowledge	*
* Financial Industry	Leadership/Influencing
Knowledge	*	Organization	&
*	Knowledge	and	coordination	skills
Understanding	of	* Coaching and people
Financial Regulations	management
(Domestic	&	* Conflict management
International) * Knowledge	and
Understanding of Risk Management and Financial Standards (Domestic & International)

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
22	Significant	System	&	Senior Credit	To	manage	overall	*	Credit	*	Strategic	Focus/	* A first degree in any	Minimum of 10 years
Influence	control	Risk Officer	credit risk profile and	Administration/Risk	Orientation	discipline.	post	qualification
Functions	Function	quality of the Group by	Management	*	Integrity	and	*	Recognised	experience in	credit
ensuring	compliance	*	Credit	Products	Discretion	professional	risk	management
with	the	approved	* Credit Analysis and	* Initiative/ Proactive	certification such as	within the Financial
credit	risk	Appraisal	*	Entrepreneurship	CFA,	CIS,	ACCA,	Services Industry, 5
management	* Loans administration	* Analytical skills /	ACA, CFP, etc.	years must have been
framework	and	/ account management	Problem	solving	at	a	senior
processes	for	*	Credit	* Resilience, Tenacity	management	and
identification,	Workout/Restructuring	and	Integrity	leadership position.
controlling, managing	* Financial analysis /	* Interpersonal skills
and reporting credit	interpretation	* Communication (oral
risk	* Facility Structuring	&	written)
	*	Leadership
	*	Coaching
	/Leadership	/
	Influencing * Initiative/Entrepreneur ship/ taking ownership * Team building / conflict management * Organization & coordination * General managerial /administration

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
23	Significant	System	&	Senior	To minimize risk of	*	Knowledge	of	*	Strategic	Focus/	* A first degree in any	Minimum of 10 years
Influence	control	Operational	loss to the Group by	operational risk best	Orientation	discipline.	post	qualification
Functions	Function	Risk Officer	defining and ensuring	practices	*	Integrity	and	*	Recognised	relevant	experience
compliance with the	* Advanced knowledge	Discretion	professional	within the Financial
approved	risk	of	operational	risk	* Initiative/ Proactive	certification such as	Services Industry , of
management	measurement	*	Entrepreneurship	CFA,	CIS,	ACCA,	which at least 5 must
framework	and	methodologies	* Analytical skills /	ACA, etc.	have	been	at
processes	for	* Banking Operations (	Problem	solving	management	and
identification,	Domestic	&	* Resilience, Tenacity	leadership position.
controlling, managing	International	and	Integrity
and	reporting	Operations)	* Interpersonal skills
operational risk	* Credit Analysis /	* Communication (oral
Appraisal	&	written)
*	Environmental	/	*	Leadership
Industry	Analysis	*	Coaching
* Investment / Portfolio	/Leadership	/
Management	Influencing
* Assets & Liabilities	*
Management	Initiative/Entrepreneur
* Financial analysis /	ship/ taking ownership
interpretation	*	Team	building	/
*	TQM	conflict	management
* Documentation	*	Organization	&
	coordination * General managerial /administration
24	Significant	System	&	Chief Internal	To ensure that the	* Audit & Investigation	*	Strategic	Focus	*	A	first	degree	A	minimum	of	10
Influence	control	Auditor	Group's internal audit	*	Financial	and	*	Integrity	and	*	Recognized	years experience in
Functions	Function	and regulatory policies	operational audit of	Discretion	professional	the	financial
are being complied	organizations	* Initiative/ Proactive	Accounting	management/accounti
	45
---	---	---	---	---	---	---	---	---	---	---	---	---	---	---	---	---	---
Type	Skills	and
Competencies
with and to ensure the	*	Financial/Banking	*	Entrepreneurship	certification such as	ng function, 5 of which
effective and efficiency	Industry	Knowledge	* Analytical skills /	ACCA, ACA, etc	must be in a senior
of	operations,	* Financial Accounting	Problem	solving	position	within	the
safeguard	of	both	*	Accounting	* Resilience, Tenacity	audit function
physical and logical	Standards	and	Integrity
assets	while	* Policy Development	* Interpersonal skills
complying	with	* Financial Reporting	* Communication (oral
policies,	applicable	* Analytical / Problem	&	written)
laws and regulations	solving skills	*	Leadership	/
	Supervisory * Team building	/
	conflict	management
	*	Organization	&
	coordination * General managerial / administration
25	Significant	System	&	IT Auditor	To	ensure	that	* Audit & Investigation	*	Strategic	Focus	* A First Degree in	A minimum of 8 years
Influence	control	business applications	*	Financial	and	*	Integrity	and	relevant	discipline.	post	qualification
Functions	Function	in various units of the	operational audit of	Discretion	Recognised	IT	experience at least 4
bank	meet	the	organizations	* Initiative/ Proactive	certifications	e.g	-	years	in	IT	audit
intended benefits and	*	Financial/Banking	*	Entrepreneurship	CISA,	etc	is	related function.
are optimally utilized.	Industry	Knowledge	* Analytical skills /	mandatory
* Financial Accounting	Problem	solving
*	Accounting	* Resilience, Tenacity
Standards	and	Integrity
* Policy Development	* Interpersonal skills
* Financial Reporting	* Communication (oral
* Analytical / Problem	&	written)
solving skills	*	Leadership	/
	Supervisory
46

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies	*	Team	building	/
	conflict	management
	*	Organization	&
	coordination * General managerial / administration
26	Significant	System	&	Business	§ To ensure measure	§ Banking Operations	§	Strategic	Focus/	§ A first degree in	Minimum of 8 years
Influence	control	Information	that would ensure the	(	Domestic	&	Orientation	relevant	discipline.	post	qualification
Functions	Function	Security	adherence	to	International	§	Integrity	and	§	Recognised	experience	in
Officer	appropriate	internal	Operations)	Discretion	professional	Compliance & Internal
control framework and	§	Accounting	§ Initiative/ Proactive	certification such as	Control	within	the
procedures so as to	§ Credit Analysis /	§	Entrepreneurship	CISSM, CISA, CGIT,	Financial	Services
minimize	loss	from	Appraisal	§ Analytical skills /	CFA,	CIS,	ACCA,	Industry , of which at
non-compliance	with	§	Environmental	/	Problem	solving	ACA,	CFP,CFE,	least 5 must have
the	policies	&	Industry	Analysis	§ Resilience, Tenacity	ACAMS,	IT	been in the Banking
procedures	§ Risk Management	and	Integrity	Certifications, etc	Sector
§	Operational	risk	§ Interpersonal skills
§	Investment	/	§ Communication (oral
Portfolio Management	&	written)
§ Assets & Liabilities	§	Leadership
Management	§	Coaching
§ Financial analysis /	/Leadership	/
interpretation	Influencing
§	TQM	§
§ Documentation	Initiative/Entrepreneur ship/ taking ownership § Team building / conflict management § Organization & coordination
47

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies	§ General managerial /administration
27	Significant	System	&	Senior Market	Define and implement	* Quantitative analysis	*	Strategic	Focus/	* A University degree	Minimum of 10 years
Influence	control	Risk/ALM	appropriate	risk	and	modeling	Orientation	in Economics or Social	post	qualification
Functions	Function	officer	management	* Sound and detailed	*	Integrity	and	Sciences	experience in market/
framework	and	knowledge of trading	Discretion	*	Recognised	liquidity	risk
policies	for	dynamics, quantitative	* Initiative/ Proactive	professional	management	within
identification,	valuation and Treasury	*	Entrepreneurship	certification such as	the Financial Services
management, control	operations	* Analytical skills /	ACIB,	CFA,	CIS,	Industry , of which at
and	reporting	of	* Deep knowledge of	Problem	solving	ACCA, ACA, CFP, ,	least 8 must have
Market and Liquidity	the Bank's trading and	* Resilience, Tenacity	etc.	been in the Banking
risks of international	treasury	products	and	Integrity	Sector and 5 years
business	* Sound knowledge of	* Interpersonal skills	must have been at a
asset	and	liability	* Communication (oral	senior	management
management	&	written)	level
* Deep understanding	*	Leadership
of the structure and	*	Coaching
complexities	of	/Leadership	/
market cycles (Local	Influencing
and	Foreign)	*
* Ability to analyse and	Initiative/Entrepreneur
interpret market and	ship/ taking ownership
economic	*	Team	building	/
information/data	conflict	management
* Detailed knowledge	*	Organization	&
of regulatory policies	coordination
and objectives	* General managerial /administration

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
28	Significant	System	&	Chief	To	manage	the	*Knowledge	and	*Strategic	Focus	First	Degree	plus	Minimum of 15 years
Influence	control	Financial	Group's	strategic,	understanding	of	*Integrity	and	Recognised	post	qualification
Functions	Function	Officer	financial management	banking	operations	Discretion	professional chartered	experience in Finance
and	regulatory	(international	&	*Initiative/	Proactive	Accounting	&	Performance
systems	to	ensure	domestic)	*Entrepreneurship	Certification	Management	role
business	integrity,	*Strategic orientation,	*Analytical	skills	/	within the Financial
protect the company's	creativity & innovation	Problem	solving	Services Industry , of
bottom line, enable	*Good	policy	*Resilience, Tenacity	which at least 10 must
profitable	and	development	and	and	Integrity	have been at a senior
sustainable	growth	management	*Interpersonal	skills	management level
and shareholder value	capabilities	*Communication (oral
creation and increase	*Financial	Acumen	&	written)
the	efficiency	and	*Finance	and	*General managerial/
quality	of	financial	Accounting	administration
operations	*Management/Cost	*Leadership/influencin
Accounting	g
*Banking	Industry	*Organization	and
Knowledge	coordination	skills
*Financial	Industry	*Coaching and people
Knowledge	management
*Financial Regulations	*Conflict management
*Financial Standards

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies
29	Significant	System	&	Chief	To	formulate	and	- Banking Operations	§ Leadership	and	- A University degree	- At least 12 years
Influence	control	Information	propose	the	IT	(Domestic	&	Communication	in relevant discipline.	post	qualification
Functions	Function	Officer;	strategy on the Banks	International	§	Coaching	/	AND	Relevant	IT	experience. 5years in
Information	Operations)	Counseling	certfication.	senior	Management
Technology,	- Deep Knowledge and	§	Team	building	position and not less
compliance	and	understanding	of	§	Organization	&	than 5 years in IT role
direction as well as	Information	Coordination
analyzing	and	Technology	§ General managerial /
reworking	existing	- Understanding of the	administration
business	processes	business	and	IT	-	Entrepreneurship
that would reshape,	strategy administration	- Customer Service
drive and deliver the	- Project Management	-	Performance
Bank's	strategic	Skills	management
objectives	-	Supplier	-	Analytical	Skills/
Management	Problem	solving
-	Change	-	Initiative	and
Management	Judgment
30	Customer	Customer	Retail	Responsible for Retail	- Excellent Business	-	Leadership	/	- First degree in any	- Minimum of 5 years
Functions	advisory	Advisory	liability	products	Development	and	Influencing	Business	related	relevant	experience
Officer	management to drive	management	-	Team	building	/	discipline	and at least 2 years in
and generate low-cost,	- Strong strategic and	conflict	management	Relevant professional	management position
stable liability for the	Analytical	Skills	-	Organization	&	certifications e,g ACIB	with responsibility in
Bank	- Advance Marketing	coordination	Retail	&	marketing
and	Sales	Skills	- General managerial /	units,	relationship
- Knowledge	and	administration	management, product
understanding	of	- Cordial Interpersonal	management	and
Nigerian Retail market	relationship	skills	Marketing and retail
-	Basic	Banking	-	Computer	sales.
Operations ( Domestic	appreciation
&	International
50
---	---	---	---	---	---	---	---	---	---	---	---	---
Type	Skills	and
Competencies Operations) - Products Management skills - Environmental / Industry analysis - Documentation
31	Customer	Customer	Ombudsman	Detailing	of	§ Excellent verbal and	*Initiative/	Proactive	A first degree in Law	Minimum of 8 years
Functions	Services	Customers'	written communication	*Analytical	skills	/	related discipline.	experience	out	of
Complaints	and	skills	Problem	solving	which at leat 3 years
resolving of the issues	§ Able to prioritise	*Resilience,	Tenacity	must have been in
raised by them.	workloads and meet	and	Integrity	financial	services
deadlines	*Interpersonal	skills	industry.
§	First	class	*Communication (oral
interpersonal	skills,	&	written)
able to communicate	*General managerial/
with a wide range of	administration
people	*Leadership/influencin
§ Ethical, focused on	g
treating	customers	*Organization	and
fairly	coordination	skills
§	Courteous	yet	*Coaching and people
assertive	management
§	Trustworthy	and	*Conflict management
reliable § Organised	and
methodical § High attention to detail § Computer literate § Respect for 51												S/N
---	---	---	---	---	---	---	---	---	---	---	---	---
Type	Skills	and
Competencies customer	and
business confidentiality good knwledge	of
legal	requirements,
industry	regulations,
organisational policies and professional codes.
32	Customer	Customer	Customer	Provide interface with	§	Excellent	*Integrity	and	A first degree in any	Minimum of 8 years
Functions	Services	Service/Conta	customers	through	interpersonal	skills,	Discretion	discipline.	experience	out	of
ct	Centre	phone, email,	chats.	including	excellent	*Initiative/	Proactive	which at leat 3 years
Manager,	Handling	customer	questioning	and	*Analytical	skills	/	must have been in
enquiries,	promote	listening skills and the	Problem	solving	financial	services
and	market	other	ability to communicate	*Resilience,	Tenacity	industry.
financial services and	with a wide range of	and	Integrity
products and, when	people	*Interpersonal	skills
required,	putting	§	Strong	customer	*Communication (oral
customers	in	direct	service	ethic	&	written)
touch with colleagues	§ Work well in a team	*General managerial/
or specialists that are	setting	administration
qualified	to	sell	§ Reliable and ethical,	*Leadership/influencin
financial products.	respecting customers'	g
confidentiality	*Organization	and
§	Organised	and	coordination	skills
methodical, with good	*Coaching and people
attention	to	detail	management
§ Confident selling and	*Conflict management
marketing	products
§	Good	numeracy
	52
---	---	---	---	---	---	---	---	---	---	---	---	---
Type	Skills	and
Competencies skills § Computer literate § Adaptable to a range of activities in any given day § Flexible working, including potential evenings and weekends
33	Customer	Customer	Private	To	articulate	and	*Excellent	client	*Leadership	/	*A First degree in any	- 8 years relevant
Function	Services	Banking	develop strategies that	relationship	Supervisory	discipline	and	experience; at least 2
Adviser	will provide direction	development/manage	*Team	building	/	Professional	of which must have
for the bank's wealth	ment	conflict	management	certifications such as	been	at	a	Senior
management activities	*Good	negotiation,	*Organization	&	ACIB,	Management position
problem-solving	and	coordination	with experience in the
conflict	resolution	*Interpersonal	skills	marketing of financial
*A deep understanding	*	Computer	services,	product
of	alternative	appreciation	/	data	development	and/or
investment strategies	entry	(word	wealth	mgt	and
*A deep Knowledge of	processing/spreadshe	portfolio/asset
capital	markets,	et/graphics)	management.
alternative	*Communication
investments & asset	(written	and	oral)
management products	*TQM
*Environmental	/
Industry	analysis
*Financial Analysis / Interpretation *Banking Operations ( Domestic & 53

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies International Operations) *Investment Portfolio Management *Money Market Trading *Marketing Presentations * Strong strategic orientation
34	Customer	Customer	Senior	-	Develop	and	-	Knowledge	and	-	Initiative	- A first degree in any	- Minimum of 10 years
Function	Function	Operations	implement	excellent	understanding of the	-	Entrepreneurship/	discipline.	experience in banking/
Officer	-	go-to –market strategy	Nigerian	payments	taking	ownership	financial	services
Electronic	to increase rollout of	landscape	-	Analytical	Skills/	institution	with
Banking	the	banks	cards,	-	Strong	alliance	Problem	solving	experience	in
channels and other	management	skills	- Financial & business	electronic	payments
technology-enabled	- Excellent customer	modelling	solutions/IT. 5 years
products and services	relationship	-	Self-Management	must have been at
across	the	Access	development/manage	- Interpersonal Skills	management level.
Group	ment	- General managerial/
- Consistently create	- Good negotiation,	administration
differentiated	e	problem-solving	and	-	Team	building	/
payment	offerings	conflict	resolution	conflict	management
through innovation and	- Creative thinking and	-	Coaching
partnering to grow the	innovative	-	Leadership	/
Bank's profitability and	-	Knowledge	and	Influencing
to deliver on strategic	understanding	of	-	Organization	and
objectives	alternatives payments	coordination skills
products - Good	product
	54

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
	Competencies development	and
	management capabilities - Knowledge of how to develop, defend and execute a business case
35	Customer	Customer	Senior	To manage the banks	*Knowledge	and	*General managerial/	A first degree in any	Minimum of 10 years
Function	Services	Lending	overall	global	understanding of the	administration	discipline.	relevant	experience
Officer	-	relationship with large	market	*Team	building	/	with at least 5 years in
Corporate	Corporate and to give	*Visibility of market	conflict	management	a management and
overall direction and	relevance	&	*Coaching	leadership role
supervision	of	the	networking	ability	*Leadership	/
group's strategies	*Strong	strategic	Influencing
	orientation	*Organization	and
	*Excellent	customer	coordination	skills
	relationship	*Initiative
	development/manage	*Entrepreneurship/
	ment	taking	ownership
	*Good	negotiation,	*Analytical	Skills/
	problem-solving	and	Problem	solving
	conflict	resolution	*Self-Management
	*Creative	and
	innovative *Knowledge	and
	understanding	of
	consumer	financial
	products *Good	product
	development	and
	55

S/N	Category	Function	Function	Roles	Required certifications	Generic skills	Minimum Qualifications	Minimum Experience
Type	Skills	and
Competencies portfolio management capabilities

Appendix C: Code Of Practice For Approved Persons:

1.1. Introduction:

1.1.1 The Code of Practice for "Approved Persons" in the financial Services Industry is issued for the purpose of helping to determine whether or not an approved person's conduct complies with the approved standards. The code sets out the following:
a. descriptions of conduct which do not comply with the relevant standards.

b. certain factors which, in the opinion of the CBN, are to be taken into account in determining whether an approved person's conduct complies with a particular standard.

1.1.2 The extant Code of Practice for Approved Persons at the time when any particular conduct takes place may be relied on so far as it establishes whether or not that conduct complies with an Approved Persons Standard. 1.1.3. The significance of the conduct identified in the Code of Practice for Approved Persons as tending to establish compliance with or a breach of an Approved persons Standard will be assessed only after all the circumstances of a particular case have been considered. Account will be taken of the context in which a course of conduct was undertaken, including the precise circumstances of the individual case, the characteristics of the particular controlled function and the behaviour to be expected in that function.

1.1.4.

a) An approved person will only be in breach of an approved standard where he is personally culpable. Personal culpability arises where an approved person's conduct was deliberate or where the approved person's standard of conduct was below that which would be reasonable in all the circumstances.

b) For the avoidance of doubt, the Approved Standards do not extend the duties of approved persons beyond those which the company owes in its dealings with customers or others.

1.1.5. In particular, in determining whether or not an approved person's conduct complies with a Standard, the CBN will take into account the extent to which an approved person has acted in a way that is stated to be in breach of an approved Standard. 1.1.6 The Code of Practice for Approved Persons (and in particular the specific examples of behavior which may be in breach of a generic description of conduct in the code) is not exhaustive of the kind of conduct that may contravene the Approved Standards. The purpose of the code is to help determine whether or not a person's conduct complies with a Standard. The code may be supplemented from time to time. The CBN will amend the code if there is a risk that unacceptable practice may become prevalent. 1.1.7 There are seven Approved Persons Standards. (see section 2 below) Standards number 1 to 4 shall apply to all approved persons. A person performing a significant influence function is also subject to the additional requirements set out in Approved Standards 5 to 7 in performing that controlled function. In the Approved Standards and in the Code of Practice for Approved Persons, a reference to "his controlled function" is a reference to the controlled function to which the approval relates. 1.1.8 In applying Approved Standards 5 to 7, the nature, scale and complexity of the business under management and the role and responsibility of the individual performing a significant influence function within the company will be relevant in assessing whether an approved person's conduct was reasonable. For example, the smaller and less complex the business, the less detailed and extensive the systems of control need to be. The CBN will be of the opinion that an individual performing a significant influence function may have breached Approved Standards 5 to 7 only if his conduct was below the standard which would be reasonable in all the circumstances. 1.1.9. Financial Institutions listed on the Nigerian Stock Exchange are subject to the Code of Corporate Governance issued by the Securities and Exchange Commission (SEC) in 2011. Institutions under the regulatory purview of the CBN in this category will thus be subject to that code as well as to the requirements and standards of the regulatory system. In forming an opinion whether approved persons have complied with its requirements, the CBN will also give due consideration to compliance with the provisions of the SEC Code of Corporate Governance. 1.1.10 All CBN regulated Financial Institutions are also subject to the CBN Code of Corporate Governance.

1.2. Factors Relating To All Approved Standards

1.2.1. In determining whether or not the particular conduct of an approved person within his controlled function complies with the Approved Standards, the following factors should be taken into account:
a) whether that conduct relates to activities that are subject to other provisions of any part of the code or b) whether that conduct is consistent with the requirements and standards of the regulatory system relevant to his company.

1.3. Factors Relating To Approved Standards 5 To 7

1.3.1. In determining whether or not the conduct of an approved person performing a significant influence function complies with Approved Standards 5 to 7, the following factors should be taken into account:
a) whether he exercised reasonable care when considering the information available to him; b) whether he reached a reasonable conclusion which he acted on; c) the nature, scale and complexity of the company's business; d) his role and responsibility as an approved person performing a significant influence function; e) the knowledge he had, or should have had, of regulatory concerns, if any, arising in the business under his control.

2.0. Code Of Practice For Approved Persons: Specific Standards 2.1. Approved Standard 1

2.1.1. "An approved person must act with integrity in carrying out his controlled function." 2.1.2. Conduct of the type described below does not comply with Approved Standard 1: A. Deliberately misleading (or attempting to mislead) by act or omission:
a) a client; or b) his company (or its auditors or an actuary appointed by his company under; or c) the CBN.

Behaviour of the type referred to above includes, but not limited to, deliberately:
a. falsifying documents; b. misleading a client about the risks of an investment; c. misleading a client about the charges or surrender penalties of investment products; d. misleading a client about the likely performance of investment products by providing inappropriate projections of future investment returns; e. misleading a client by informing him that products require only a single payment when that is not the case; f. mismarking the value of investments or trading positions; g. procuring the unjustified alteration of prices on illiquid or off-exchange contracts, or both; h. misleading others within the company about the credit worthiness of a borrower; i. providing false or inaccurate documentation or information, including details of training, qualifications, past employment record or experience; j. providing false or inaccurate information to the company (or to the company's auditors or an actuary appointed by the company k. providing false or inaccurate information to the CBN; l. destroying, or causing the destruction of, documents (including false documentation), or tapes or their contents, relevant to misleading (or attempting to mislead) a client, his company, or the CBN; m. failing to disclose dealings where disclosure is required by the company's personal account dealing rules; n. misleading others in the company about the nature of risks being accepted.

B. Deliberately recommending an investment to a customer, or carrying out a discretionary transaction for a customer where the approved person knows that he is unable to justify its suitability for that customer.

C. Deliberately failing to inform, without reasonable cause:
(1) a customer; or (2) his company (or its auditors or an actuary appointed by his company or (3) the CBN; of the fact that their understanding of a material issue is incorrect, despite being aware of their misunderstanding.

Behaviour of the type referred to above includes, but not limited to, deliberately:
a. failing to disclose the existence of falsified documents; b. failing to rectify mismarked positions immediately.

D. Deliberately preparing inaccurate or inappropriate records or returns in connection with a controlled function.

Behaviour of the type referred to above includes, but not limited to, deliberately:
a. preparing performance reports for transmission to customers which are inaccurate or inappropriate (for example, by relying on past performance without appropriate warnings); b. preparing inaccurate training records or inaccurate details of qualifications, past employment record or experience; c. preparing inaccurate trading confirmations, contract notes or other records of transactions or holdings of securities for a customer, whether or not the customer is aware of these inaccuracies or has requested such records.

E. Deliberately misusing the assets or confidential information of a client or of his company. Behaviour of the type referred to above includes, but is not limited to, deliberately:
a. front running client orders; b. carrying out unjustified trading on client accounts to generate a benefit (whether direct or indirect) to the approved person (that is, churning);
c. misappropriating a client's assets, including wrongly transferring to personal accounts cash or securities belonging to clients; d. wrongly using one client's funds to settle margin calls or to cover trading losses on another client's account or on company accounts; e. using a client's accounts or funds for purposes other than those for which they were provided; f. retaining a client's funds wrongly; g. pledging the assets of a client as security or margin in circumstances where the company is not permitted to do so.

F. Deliberately designing transactions so as to disguise breaches of requirements and standards of the regulatory system. G. Deliberately failing to disclose the existence of a conflict of interest in connection with dealings with a client. H. Deliberately not paying due regard to the interests of a customer.

I. Deliberate acts, omissions or business practices that could be reasonably expected to cause consumer detriment

2.2.1. "An approved person must act with due skill, care and diligence in carrying out his controlled function." 2.2.2. Conduct of the type described below do not comply with Approved Standard 2: A. Failing to inform (1) a customer; or (2) his company (or its auditors or an actuary appointed by his company; of material information in circumstances where he was aware, or ought to have been aware, of such information, and of the fact that he should provide it.

Behaviour of the type referred to above includes, but not limited to:
a. failing to explain the risks of an investment to a customer; b. failing to disclose to a customer details of the charges or surrender penalties of investment products; c. mismarking trading positions; d. providing inaccurate or inadequate information to a company, its auditors or an actuary appointed by his company; e. failing to disclose dealings where disclosure is required by the company's personal account dealing rules.

B. Recommending an investment to a customer, or carrying out a discretionary transaction for a customer, where he does not have reasonable grounds to believe that it is suitable for that customer. C. Undertaking, recommending or providing advice on transactions without a reasonable understanding of the risk exposure of the transaction to a customer. Behaviour of the type referred to above includes, but not limited to, recommending transactions in investments to a customer without a reasonable understanding of the liability (either potential or actual) of that transaction. D. Undertaking transactions without a reasonable understanding of the risk exposure of the transaction to the company. Behaviour of the type referred to above includes, but not limited to, trading on the company's own account without a reasonable understanding of the liability (either potential or actual) of the transaction. E. Failing without good reason to disclose the existence of a conflict of interest in connection with dealings with a client.

F. Failing to provide adequate control over a client's assets Behaviour of the type referred to above includes, but is not limited to:
a. failing to segregate a client's assets; b. failing to process a client's payments in a timely manner.

G. Continuing to perform a controlled function despite having failed to meet the standards of knowledge and skill set out by the CBN for that controlled function. reason. H. Failing to pay due regard to the interests of a customer, without good

2.3.1. "An approved person must observe proper standards of market conduct in carrying out his controlled function." 2.3.3. A factor to be taken into account in determining whether or not an approved person's conduct complies with this Approved Standard is whether he, or his company, has complied relevant market codes and exchange rules. Compliance with the code or rules described above will tend to show compliance with this Approved Standard.

2.4.1. "An approved person must deal with the CBN and with other regulators in an open and cooperative wayand must disclose appropriately any information of which the CBN would reasonablyexpect notice."
2.4.2. For the purpose of this Standard, regulators in addition to the CBN are those which have recognised jurisdiction in relation to regulated activities and power to call for information from the approved person in connection with his controlled function or (in the case of an individual performing a significant influence function) in connection with the business for which he is responsible. This may include the NDIC, SEC or an overseas regulator. 2.4.3. Conduct of the type described below do not comply with Approved Standard 4: A. Failing to report promptly in accordance with his company's internal procedures (or if none exist direct to the regulator), information which it would be reasonable to assume would be of material significance to the regulator, whether in response to questions or otherwise. There is no duty on an approved person to report such information directly to the CBN unless he is one of the approved persons responsible within the company for reporting matters to the regulator. However, if an approved person takes steps to influence the decision so as not to report to the regulator or acts in a way that is intended to obstruct the reporting of the information to the regulator, then the CBN will, in respect of that information, view him asbeing one of those within the company who has taken on responsibility for deciding whetherto report that matter to the regulator. In determining whether or not an approved person's conduct under (A) above complies with Approved Standard 4, the following are factors which, in the opinion of the CBN, are to be taken into account:
i. the likely significance to the CBN of the information which it was reasonable for the individual to assume; ii. whether the information is related to the individual himself or to his company; iii. whether any decision not to report the matter internally was taken after reasonable enquiry and analysis of the situation.

B. Where the approved person is, or is one of the approved persons who is, responsible within the company for reporting matters to the CBN, failing promptly to inform the CBN of information of which he is aware and which it would be reasonable to assume would be of material significance to the CBN, whether in response to questions or otherwise. In determining whether or not an approved person's conduct above complies with Approved Standard 4, the following are factors which, in the opinion of the CBN, are to be taken into account:
I. the likely significance of the information to the CBN which it was reasonable for the approved person to assume; II. whether any decision not to inform the CBN was taken after reasonable enquiry and analysis of the situation.

C. Failing without good reason to:
I. inform a regulator of information of which the approved person was aware in response to questions from that regulator; II. attend an interview or answer questions put by a regulator, despite a request or demand having been made; III. supply a regulator with appropriate documents or information when requested or required to do so and within the time limits attaching to that request or requirement.

2.5.1. "An approved person performing a significant influence function must take reasonable steps to ensurethat the business of the company for which he is responsible in his controlled function isorganised so that it can be controlled effectively." 2.5.2. Conduct of the type described below do not comply with Approved Standard 5: A. Failing to take reasonable steps to apportion responsibilities for all areas of the business under the approved person's control. B. Failing to take reasonable steps to apportion responsibilities clearly amongst those to whom responsibilities have been delegated. Behaviour of the type referred to above includes, but is not limited to:
I. implementing confusing or uncertain reporting lines; II. implementing confusing or uncertain authorisation levels; III. implementing confusing or uncertain job descriptions and responsibilities C. In the case of an approved person who is responsible for dealing with the apportionment of responsibilities, failing to take reasonable care to maintain a clear and appropriate apportionment of significant responsibilities among the company's directors, senior managers and approved persons performing significant functions. Behaviour of the type referred to above includes, but is not limited to:
I. failing to review regularly the significant responsibilities which the company is required to apportion; II. failing to act where that review shows that those significant responsibilities have not been clearly apportioned.

D. Failing to take reasonable steps to ensure that suitable individuals are responsible for those aspects of the business under the control of the individual performing a significant influence function. Behaviour of the type referred to above includes, but is not limited to:
I. failing to review the competence, knowledge, skills and performance of staff to assess their suitability to fulfill their duties, despite evidence that their performance is unacceptable; II. giving undue weight to financial performance when considering the suitability or continuing suitability of an individual for a particular role; III. allowing managerial vacancies which put at risk compliance with the requirements and standards of the regulatory system to remain, without arranging suitable cover for the responsibilities.

2.5.3. Strategy and plans will often dictate the risk which the business is prepared to take on and high level controls will dictate how the business is to be run. If the strategy of the business is to enter high-risk areas, then the degree of control and strength of monitoring reasonably required within the business will be high. In organising the business for which he is responsible, the approved person performing a significant influence function should bear this in mind.

2.5.4. Apportionment Of Responsibilities

In order to comply with the obligations of Approved Standard 5, the approved person performing a significant influence function may find it helpful to review whether each area of the business for which he is responsible has been clearly assigned to a particular individual or individuals.

2.5.5. Authorization Level And Job Description

Where members of staff have particular levels of authorisation, these should be clearly set out and communicated to staff. It may be appropriate for each member of staff to have a job description of which he is aware.

2.5.6. Suitability Of Individual

The appropriate approved person performing a significant influence function should take reasonable steps to satisfy himself, on reasonable grounds that each area of the business for which he is responsible has in place appropriate policies and procedures for reviewing the competence, knowledge, skills and performance of each individual member of staff.

If an individual's performance is unsatisfactory, then the appropriate approved person (if any) performing a significant influence function should review carefully whether to allow that individual to continue in position. In particular, if he is aware of concerns relating to the compliance with requirements and standards of the regulatory system (or internal controls) of the individual concerned, or of staff reporting to that individual, the approved person performing a significant influence function should take care not to give undue weight to the financial performance of the individual or group concerned when considering whether any action should be taken. An adequate investigation of the concerns should be undertaken (including, where appropriate, adherence to internal controls). The approved person performing a significant influence function should satisfy himself, on reasonable grounds, that the investigation is appropriate, the results are accurate and that the concerns do not pose an unacceptable risk to compliance with the requirements and standards of the regulatory system (see in particular Approved Standard 6.

2.5.7. Temporary Vacancies

In organising the business, the approved person performing a significant influence function should pay attention to any temporary vacancies which exist. He should take reasonable steps to ensure that suitable cover for responsibilities is arranged. This could include taking on temporary staff or external consultants. An approved person performing a significant influence function should assess the risk that is posed to compliance with the requirements and standards of the regulatory system as a result of the vacancy, and the higher the risk the greater the steps he should take to fill the vacancy. It may be appropriate to limit or suspend the activity if appropriate cover for responsibilities cannot be arranged. To the extent that those vacancies are in respect of one of the customer functions, they may only be filled by persons approved for that function. 2.6. Approved Standard 6 2.6.1. "An approved person performing a significant influence function must exercise due skill, care and diligence in managing the business of the company for which he is responsible in his controlled function." 2.6.2. Conduct of the type described below do not comply with Approved Standard 6: A. Failing to take reasonable steps to adequately inform himself about the affairs of the business for which he is responsible. Behaviour of the type referred to above includes, but is not limited to:
I. permitting transactions without a sufficient understanding of the risks involved; II. permitting expansion of the business without reasonably assessing the potential risks of that expansion; III. inadequately monitoring highly profitable transactions or business practices or unusual transactions or business practices; IV. accepting implausible or unsatisfactory explanations from subordinates without testing the veracity of those explanations; V. failing to obtain independent, expert opinion where appropriate:
B. Delegating the authority for dealing with an issue or a part of the business to an individual or individuals (whether in-house or outside contractors) without reasonable grounds for believing that the delegate had the necessary capacity, competence, knowledge, seniority or skill to deal with the issue or to take authority for dealing with part of the business. C. Failing to take reasonable steps to maintain an appropriate level of understanding about an issue or part of the business that he has delegated to an individual or individuals (whether in-house or outside contractors). Behaviour of the type referred to above includes but is not limited to:
I. disregarding an issue or part of the business once it has been delegated; II. failing to require adequate reports once the resolution of an issue or management of part of the business has been delegated; III. accepting implausible or unsatisfactory explanations from delegates without testing their veracity.

D. Failing to supervise and monitor adequately the individual or individuals (whether in-house or outside contractors) to whom responsibility for dealing with an issue or authority for dealing with a part of the business has been delegated. Behaviour of the type referred to above includes, but is not limited to:
I. failing to take personal action where progress is unreasonably slow, or where implausible or unsatisfactory explanations are provided; II. failing to review the performance of an outside contractor in connection with the delegated issue or business.

2.6.3. In determining whether or not the conduct of an approved person performing a significant influence function complies with Approved Standard 6, the following are factors which, in the opinion of the CBN, are to be taken into account:
I. the competence, knowledge or seniority of the delegate; and II. the past performance and record of the delegate.

2.6.4. An approved person performing a significant influence function will not always manage the business on a day-to-day basis himself. The extent to which he does so will depend on a number of factors, including the nature, scale and complexity of the business and his position within it. The larger and more complex the business, the greater the need for clear and effective delegation and reporting lines. The CBN will look to the approved person performing a significant influence function to take reasonable steps to ensure that systems are in place which result in issues being addressed at the appropriate level. When issues come to his attention, he should deal with them in an appropriate way.

2.6.5. Knowledge About The Business

a. It is important for the approved person performing a significant influence function to understand the business for which he is responsible. An approved person performing a significant influence function is unlikely to be an expert in all aspects of a complex financial services business. However, he should understand and inform himself about the business sufficiently to understand the risks of its trading, credit or other business activities.

b. It is important for an approved person performing a significant influence function to understand the risks of expanding the business into new areas and, before approving the expansion, he should investigate and satisfy himself, on reasonable grounds, about the risks, if any, to the business.

c. Where unusually profitable business is undertaken, or where the profits are particularly volatile or the business involves funding requirements on the company beyond those reasonably anticipated, he should require explanations from those who report to him. Where those explanations are implausible or unsatisfactory, he should take steps to test the veracity of those explanations.

d. Where the approved person performing a significant influence function is not an expert in a business area, he should consider whether he or those with whom he works have the necessary expertise to provide him with an adequate explanation of issues within that business area. If not he should seek an independent opinion from elsewhere within or outside the company.

2.6.6. Delegation

a. An approved person performing a significant influence function may delegate the investigation, resolution or management of an issue or authority for dealing with a part of the business to individuals who report to him or to others.

b. The approved person performing a significant influence function should have reasonable grounds for believing that the delegate has the competence, knowledge, skill and time to deal with the issue. For instance, if the compliance department only has sufficient resources to deal with day-to-day issues, it would be unreasonable to delegate to it the resolution of a complex or unusual issue without ensuring it had sufficient capacity to deal with the matter adequately.

c. If an issue raises questions of law or interpretation, the approved person performing a significant influence function may need to take legal advice. If appropriate legal expertise is not available in-house, he may need to consider appointing an appropriate external adviser.

d. The CBN recognises that the approved person performing a significant influence function will have to exercise his own judgment in deciding how issues are dealt with, and that in some cases that judgment will, with the benefit of hindsight, be shown to have been wrong. He will not be in breach of Approved Standard 6 unless he fails to exercise due and reasonable consideration before he delegates the resolution of an issue or authority for dealing with a part of the business and fails to reach a reasonable conclusion. If he is in doubt about how to deal with an issue or the seriousness of a particular compliance problem, then, although he cannot delegate to the CBN the responsibility for dealing with the problem or issue, he can speak to the CBN to discuss his approach.

2.6.7. Continuing Responsibility Where An Issue Has Been Delegated

Although an approved person performing a significant influence function may delegate the resolution of an issue, or authority for dealing with a part of the business, he cannot delegate responsibility for it. It is his responsibility to ensure that he receives reports on progress and questions those reports where appropriate. For instance, if progress appears to be slow or if the issue is not being resolved satisfactorily, then the approved person performing a significant influence function may need to challenge the explanations he receives and take action himself to resolve the problem. This may include increasing the resource applied to it, reassigning the resolution internally or obtaining external advice or assistance. Where an issue raises significant concerns, an approved person performing a significant influence function should act clearly and decisively. If appropriate, this may be by suspending members of staff or relieving them of all or part of their responsibilities.

2.7.1. "An approved person performing a significant influence function must take reasonable steps to ensurethat the business of the company for which he is responsible in his controlled function complies with the relevant requirements and standards of the regulatory system." 2.7.2. Conduct of the type described below does not comply with Approved Standard 7: A. Failing to take reasonable steps to implement (either personally or through a compliance department or other departments) adequate and appropriate systems of control to comply with the relevant requirements and standards of the regulatory system in respect of its regulated activities. In the case of an approved person who is responsible for overseeing the company's obligation, failing to take reasonable care to oversee the establishment and maintenance of appropriate systems and controls. B. Failing to take reasonable steps to monitor (either personally or through a compliance department or other departments) compliance with the relevant requirements and standards of the regulatory system in respect of its regulated activities. C. Failing to take reasonable steps adequately to inform himself about the reason why significant breaches (whether suspected or actual) of the relevant requirements and standards of the regulatory system in respect of its regulated activities may have arisen (taking account of the systems and procedures in place). Behaviour of the type referred to above includes, but is not limited to, failing to investigate what systems or procedures may have failed including, where appropriate, failing to obtain expert opinion on the adequacy of the systems and procedures. D. Failing to take reasonable steps to ensure that procedures and systems of control are reviewed and, if appropriate, improved, following the identification of significant breaches (whether suspected or actual) of the relevant requirements and standards of the regulatory system relating to its regulated activities. Behaviour of the type referred to above includes, but is not limited to: a. unreasonably failing to implement recommendations for improvements in systems and procedures; b. unreasonably failing to implement recommendations for improvements to systems and procedures in a timely manner.

E. In the case of the money laundering reporting officer, failing to discharge the responsibilities imposed on him by the company F. In the case of an approved person performing a significant influence function responsible for compliance failing to take reasonable steps to ensure that appropriate compliance systems and procedures are in place. G. The CBN expects an approved person performing a significant influence function to take reasonable steps both to ensure his company's compliance with the relevant requirements and standards of the regulatory system and to ensure that all staff are aware of the need for compliance.

Where the approved person is a proprietary trader, failing to maintain and comply with appropriate systems and controls in relation to that activity.

2.7.3. Systems Of Control

An approved person performing a significant influence function need not himself put in place the systems of control in his business. Whether he does this depends on his role and responsibilities. He should, however, take reasonable steps to ensure that the business for which he is responsible has operating procedures and systems which include well-defined steps for complying with the detail of relevant requirements and standards of the regulatory system and for ensuring that the business is run prudently. The nature and extent of the systems of control that are required will depend upon the relevant requirements and standards of the regulatory system, and the nature, scale and complexity of the business.

2.7.4. Possible Breaches Of Regulatory Requirements

Where the approved person performing a significant influence function becomes aware of actual or suspected problems that involve possible breaches of relevant requirements and standards of the regulatory system falling within his area of responsibility, then he should take reasonable steps to ensure that they are dealt with in a timely and appropriate manner. This may involve an adequate investigation to find out what systems or procedures may have failed and why. He may need to obtain expert opinion on the adequacy and efficacy of the systems and procedures.

2.7.5. Review And Improvement Of Systems And Procedures

Where independent reviews of systems and procedures have been undertaken and result in recommendations for improvement, the approved person performing a significant influence function should ensure that, unless there are good reasons not to, any reasonable recommendations are implemented in a timely manner. What is reasonable will depend on the nature of the inadequacy and the cost of the improvement. It will be reasonable for the approved person performing a significant influence function to carry out a cost benefit analysis when assessing whether the recommendations are reasonable. Notes: In several places in the document, the words "he" and "his' were used to denote an approved person. This does not indicate a male person only but refers to both male and female approved persons. It means either "he" or "she" and "his" or "her'