Whistleblower Policy

1. Purpose

Kwaso Community Bank is committed to the highest standards of ethical conduct, transparency and accountability. This Whistleblower Policy provides a safe and confidential mechanism for employees, directors, customers, suppliers and the general public to report concerns about suspected fraud, corruption, misconduct or violations of law or bank policy.

2. What You Can Report

• Fraud or theft — misappropriation of bank funds, customer deposits or assets.
• Corruption or bribery — offering or accepting improper inducements.
• Money laundering — suspected violations of the Anti-Money Laundering Act, 2020 (Act 1044).
• Financial misstatement — deliberate manipulation of accounts or financial reports.
• Regulatory violations — breaches of Bank of Ghana directives, Act 930 or other applicable laws.
• Conflicts of interest — undisclosed personal interests affecting bank decisions.
• Abuse of authority — harassment, discrimination or misuse of position.
• Health & safety violations — dangers to employees or customers at bank premises.
• Data privacy breaches — unauthorized access to or misuse of personal data.

3. How to Report

You may raise concerns through any of the following confidential channels:

4. What to Include

To help us investigate effectively, please include as much detail as possible:

• Description of the concern or incident.
• Names and positions of individuals involved (if known).
• Dates, times and locations.
• Any supporting evidence or documents.
• Your contact information (optional — anonymous reports accepted).

5. Investigation Process

• Reports are reviewed by the Compliance Officer or the Audit Committee of the Board.
• An acknowledgement is sent within 3 business days (where contact details are provided).
• A preliminary assessment determines the appropriate investigation approach.
• Investigations are conducted impartially, thoroughly and confidentially.
• Outcomes are communicated to the reporter where possible, subject to privacy and legal constraints.
• Substantiated cases result in disciplinary action, termination, or referral to law enforcement.

6. Protection from Retaliation

Any person who retaliates against a whistleblower will face serious disciplinary action, up to and including termination and legal proceedings. This protection applies to:

• Employees and directors of KCB.
• Contractors, suppliers and other business partners.
• Customers and members of the public.

7. Governance

This policy is approved by the Board of Directors and reviewed annually. The Audit Committee has oversight of the whistleblower programme and reports to the Board on all matters arising. This policy complies with the Whistleblower Act, 2006 (Act 720) of Ghana.