August 7 2019 www.firstbanknigeria.com Outline Macro, T rending - - PowerPoint PPT Presentation

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STRATEGIC VENDORS’ ENGAGEMENT SESSEION. MACRO-ECONOMIC UPDATE

August 7 2019

Outline

Macro, T rending News…..Global Macro, T rending News…..Domestic Market Updates

Macro Trends - Global

Declining trend in global

• utput growth
• Fed cut rates by 25bps
• Escalation of trade tensions between

US & China

• China’s growth expected to slide to

6.2%

• A new round of sanctions imposed on

Iran.

• Possible hard BREXIT

, given the new PM stance

• Vulnerabilities in major fjnancial

markets

• Rising public & private debts in some

EM and DMs

• ECB is going back to quantitative

easing.

Macro Trends - Global

The environment is changing - more accommodative monetary policy stance globally,

in response to low infmation & deteriorating growth prospects

Macro Trends - Domestic

• Fragile and uneven economic growth
• 2.01% y-o-y expansion in Q1 2019 (0.12% rise

from Q1 2018 and 0.38% decline from Q4 2018)

• IMF just increased forecast of economic growth to

2.3% from 2.0%.

• Short-term rates trajectory suggests a deliberate

easing of liquidity conditions, YTD rates down by 470bps;

• Capital fmows dwindling from about $11.86bn in Q1

2019

• Policy uncertainties
• EM sell-ofgs, triggered risk reduction
• Geopolitical risks and security concerns
• Infmation currently at 11.22% y-o-y June 2019 from a

year-peak of 11.40% in May 2019, 0.20% lower than 11.37% in January 2019 .

General market apathy, portends relatively subdued growth prospects.

Market Updates ……..

Central Bank of Nigeria:

• Plans to achieve 80% fjnancial inclusion target by 2020
• To adopt systemic tightening
• Target to refocus banks to do consumer credits
• Recently slashed the maximum earning amount for standing deposit facilities to N2bn

from N7.5bn

• Reduced mop up activities
• Set Loan to Deposit ratio to 60% for DMBs, a must compliance by Sept 2019.
• No change in CRR regime.
• Maintained MPR @ 13.5%, all other key rates and ratios unchanged.

Market Updates ……..

• A declining interest rate environment; trend expected to be sustained in

near term.

Market Updates ……..

• Near direct correlation between Oil Price & FX Reserves.
• Joint destiny? As long as Oil revenues remain the major source of

reserves

• Volatile Oil prices; currently around $61/bbl
• FX reserves $44.8bn from $45bn at the end of H1 2019

Triggers for review of FX policy set at: Reserves below $30bn & oil

price falls below $50/bbl.

Market Updates ……..

• Multiple FX windows still subsists
• CBN – 306/307
• Wholesale SMIS– 357/358
• Retail SMIS – 330/345
• Retail SMIS (Yuan) – 49/51
• SME/Invisibles – 360
• NAFEX – 362.50/363.5
• Parallel – 358/360
• FX reserves & oil price, supportive of

current FX policy.

• No plans to review structure, except

where reserves fall below $30bn and oil price falls below $50/bbl.

• More controls around FX demand

expected, e.g. Dairy products may be included in the restricted items.

Opportunities

• Take advantage of the various sources of FX to close out FX obligations
• Non Deliverable Forwards (NDFs) can be used to hedge exposure to eligible FX risk
• Coys with access to FCY funding may take advantage of FCY loans and hedge with

Cross Currency Swaps.

• Fixed Income market profgers short term investment opportunities for idle funds.

11

Thank you

OUTSOURCING FOR EFFICIENCY VENDOR ENGAGEMENT SESSION 4 POINTS 7.8.2019

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Outline

• Defjnition and Examples of Outsourcing
• Why Outsource?
• Key Considerations
• Underage Employment
• Work Life balance
• Work Life Integration

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EXAMPLES

Human Resource Management Facilities Management Supply Chain management Content Writing Engineering Accounting

DEFINITION

A process in which a company contracts with another company to manage services that it needs but it doesn’t want to provide itself.

Defjnition and Examples of Outsourcing

Lowering of Costs and Improving the effjcient allocation of resources within a company. It allows a company redirect its attention to its own competencies. Outsourcing Requires a high degree of standardization and management control in order to be efgective.

WHY OUTSOURCE?

T alent Resourcing – Right skills and competencies Right Hiring – Background Checks Performance and Productivity Cost Savings Security Risks - Fraud Negative Public Relations - Brand

KEY CONSIDERATIONS

LEGAL WORKING AGE The legal working age is the minimum age required by law for a person to work in each country or jurisdiction. Some countries go as low as 13 for easy work (Kenya), some 15 or 16 and 18 for restricted working hours and type of work and unrestricted respectively(Kenya and South Africa. NIGERIA  The minimum age for employment is 12 years . A child (under 12 years) cannot be employed to work in any capacity except where in a family enterprise on light work of an agricultural, horticultural or domestic nature approved by the Government and must not be required to lift, carry or move anything so heavy as to injure his physical development.  Minimum age for employment in industrial undertakings is 15 years, however this cut-ofg age is not applicable to the work done by young persons in technical schools or similar institutions if the work is approved by Ministry of Education.  Young persons under the age of sixteen may not be employed to work underground or on machine work or on public

• holidays. They are prohibited to work in circumstances where they are unable to return to their place of residence

except with the approval of the authorized Labour offjcer.  Minimum age for hazardous work is 18 years.

Source§ 18 of the Constitution of the federal Republic of Nigeria 1999. §59(1-5) of the Labour Act(Cap L1LFN 2004)

UNDERAGE EMPLOYMENT

THE CHILD’s RIGHTS ACT PROHIBITS THE FOLLOWING: -  The use of children for the purpose of begging for alms  Use of children as slaves or for practices similar to slavery such as sale or traffjcking  Use of children for hawking of goods or services on main city streets, brothels or highways  Use of children for any purpose that deprives the child of the opportunity to attend and remain in school as provided for under the Compulsory, Free Universal Basic Education Act.  Procurement or ofgering for prostitution or for the production of pornography  Procurement or ofgering for any activity in the production or traffjcking of illegal drugs and any other activity relating to illicit drugs as specifjed in the National Drug Law Enforcement Agency Act.  Violation of this provision is punishable with imprisonment for a term of ten years.  Minimum age for harzardous work is 18 years.

Source§ 59(5-8) & 60 of the Labour Act(Cap L1LFN 2004); § 28 -30 of the Child’s Rights Act, 2003

UNDERAGE EMPLOYMENT CONT’D

DEFINITION OF WORK LIFE BALANCE – The division of one’s time and focus between working and family or leisure activities. EXAMPLES;-  Creation of Flexible leave policies  Foster a healthy work environment – creating healthy events like aerobic classes outside the work place. Provision of a healthy meals in the offjce canteens  Create family-friendly policies like children education loans, family bonding events etc. BENEFITS: -  Reduction of Stress and health issues  Prevention of Burnouts in the workplace

WORK LIFE BALANCE

DEFINITION OF WORK LIFE INTEGRATION – This term is used instead of Work Life Balance because the latter evokes a binary opposition between work and life. Work Life Integration is an approach that creates more synergies between all areas that defjne “life": work, home/family, community,personal well-being and healthe divison of one’s time and focus between working and family or leisure activities. Management of work responsibilities alongside personal & family needs. WORK LIFE INTEGRATION INITIATIVES: -  Flexi Work hours – Ofg Site Work  Family care leave  On site child care facilities – Crèches etc.

WORK LIFE INTEGRATION

THANK YOU

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FirstBank Vendors BCM Engagement & Awareness Session

August, 2019

Building Resilience in Our Vendors Businesses

Outline

2

• Introduction
• Recent Developments and Implications for Vendors
• Global Top 10 Threats to Business Continuity & Implications

for Vendors

• Organisational Resilience and Its Imperatives for Vendors
• Business Continuity Management
• Our Collective Roles & Responsibilities
• Wrap-Up

Our Vision & Mission Statements

3

Our Vision: Our Mission:

To be the clear leader and Nigeria’s bank of fjrst choice To remain true to our name by providing the best fjnancial services possible

4

ction {The Big Picture: Success in Business Organisation}

• At the core of every

business organization are 3 basic

• bjectives

by which success may be defjned.

• It may be said that a

business survives and develops in

• rder

to provide a profjt, or makes a profjt by which it can survive and develop. Survival Survival . Profitability. . Profitability. Growth and development Growth and development

Introduction {The Big Picture: Success in Business Organisation (cont’d)}

5

Driving Business growth Delivering Business Value Containing Cost Improving Customer Service Strengthening Brand Creating New Product lines Convenience Driving Production Effjciency Flexibility Managing Perception Growing Customer Base Product Innovation Process Automation Wide service

• fgerings

Integrated Marketing Communication Expanding to new markets Speed Outsourcing Increasing Service channels Media Campaigns In the pursuit of these objectives and creating value, organizations are faced with several challenges, which may put their objectives and success at jeopardy. Hence, the compelling reason for building organizational Resilience

6

Recent Developments and Implications for Organizations

• Globally, the year has witnessed signifjcant developments and business

disruptions with far reaching implications for countries and organisations.

• These include natural disasters and other threats such as fmood, wild fjre,

pandemics (Ebola), terrorism, insurgencies, cyber attack, air accidents, increasing regulatory demands e.t.c.

• This has heightened greater interest in resilience by organizations to increase

their adaptive capacity to sudden shocks or disruptive incidents. In this regard, Business Continuity Management (BCM) is now on the front burner of Board and Management of organizations.

• ISO22301 standard encompasses a wider societal security concerns and

reinforces Business Continuity Management role in societal protection and ensures organizations can respond to incidents, emergencies, disasters and remain a-going-concern.

• The ability to identify, prioritize, and respond to incidents or disruptions (man-

made or natural disasters) is critical in preventing fjnancial losses, damage to reputation and building organizational resilience.

Global Top 10 Threats to Business Continuity in 2019

7

According to the latest 2019 report from the Annual Survey published by the Business Continuity Institute (BCI), in association with British Standard Institution (BSI) the top 10 threats are the greatest concern for

• rganizations.

The report assessed the business preparedness of organizations in countries worldwide and shows that more than 85% of Business Continuity Managers expressed grave concerns on the following:

• 1. Cyber attack and data breach -1
• 2. Unplanned IT & telecom outages – 2
• 3. Adverse Weather & Natural Disaster - 3
• 4. Critical Infrastructure Failure – 4
• 5. Reputation Incident - 5
• 6. Regulatory Changes - 6
• 7. Lack of T

alents/Key Skills -7

• 8. Supply Chain Disruption – down 8
• 9. Interruption to Utility Supply – 9

10.Political Change -10

8

Organisational Resilience and its Imperatives for Vendors

Organisational resilience is ‘the ability of an organisation to anticipate, prepare for, respond and adapt to incremental change and sudden disruptions in order to survive, grow and be Profjtable. Resilience is more than just increasing the robustness of a business – it’s about looking forward to see what might happen and striving to stay one step ahead.

The four pillars of resilience are:

• Governance: for resilience to be efgective, key stakeholders and T
• p management must

be aware of and ready to implement changes.

• Resilience: taking steps to make a business more robust before any business disruption

is critical.

• Business continuity: Organizations that are hit by disaster and do not have a continuity

and disaster recovery plan may not survive the incident or go into extinction. Business continuity is about having a plan to continue critical services within pre-defjned time- scales in order to meet expectations of interested parties.

• Crisis management: it’s important to have a crisis communication plan in place for

implementation/invocation during a major incident crisis. This will help to reduce reputational damage which can impact on the goodwill of organizations.

Organisational Resilience and its Imperatives for Vendors (Cont’d)

9

Expanded scope Oversee all service providers, affjliates, partnerships and other third parties Governance and accountability Defjne responsibilities of the board, senior management, and relationships managers End-to-end risk management Formalize risk management across the life-cycle and risk domains. Greater scrutiny with high risk vendors. Due Diligence Access how vendors are sought, vetted, selected Contracts Do you have them? Do they have the appropriate clauses? Execute a contract inventory. Monitoring Timely and efgective reporting in vendor relationships. Demonstrate you have suffjcient visibility and control. Use of scorecards and dashboards Compliance Identify all relevant compliance requirements and document how they are being met Independent Reviews Do your vendors…’Say what they do?’ and ‘Do what they say’. Risks are documented and controls in place. Business Continuity Consider the systemic implications of outsourcing and potential third party failures

Regulators globally have issued heightened standards and guidance for third party’s. These cover most regulatory expectations….

Business Continui ty Culture

Resilien ce Respons e Recover y

Organisational Resilience and its Imperatives for Vendors (Cont’d)

Building Organisational Resilience requires having a robust Business Continuity Management System (BCMS) in Place. Business Continuity Institute (BCI) defjnes BCM as a:

• holistic management process
• identifjes potential impacts
• framework for resilience and response capability
• safeguard interests of key stakeholders

Business Continuity – A Time Line Perspective

Critical Time Period

Time Disruption Occurs

Normal

• perations

restored

Business as Usual

Emergency Operations Center activated

Planning/Resilience Stage Recovery Stage Normal Operations Emergency Response

Event Stages

Resilience continues lessons learned

Our Collective Roles and Responsibilities

12

• Provision of quality Service and meeting expectations in the

event of the unforeseen emergencies or disruptions.

• Compliance to all regulatory requirements e.g tax clearance.
• Regularly assess and monitor the efgectiveness of vendor

program where there are dependencies on other vendors.

• Adherence to Service Level Agreements (SLAs)
• Adherence to the non-disclosure agreement and Information

Security Policies

• Capacity Building and T

alents Retention

• Have a documented Business Continuity Plan
• Exercising and T

esting of Business Continuity/Disaster Recovery Plans

• Implementing controls and measures for managing

Continuity risks.

• Embed Operational Risk Management Culture

Conclusion

13

• T
• achieve Organizational Resilience, we are responsible for

identifying not only the big risks but also the under-rated issues that may just seem “business as usual” and can easily be missed.

• Organisational resilience is about being forward-looking –

anticipating, preparing for, responding and adapting to change.

• In conclusion, it is important to fully imbibe risk management

culture for continuous organizational survival, sustainable growth and profjtability.

Conclusion

14

2019 First Bank Vendor Engagement Session

August, 2019

2

Outline for today’s session

2

• Best in Class Procurement Function
• Building Resilience in our vendors’

businesses

• Voice of the Vendor-Interactive

session with FBN

3

202 201 9

Next set of goals

First Bank’s goal over the next 12 months is to achieve a Best in Class Procurement Function Measured by our level of :  Transparency and effjciency  Competitiveness  Value creation

4

The journey has started…..

Transparency and Effjciency Automation of end to end processes allows us to have:  Visibility into our spend  Determine and analyze our key spend areas  Identify our strategically important stakeholders  Minimize procurement to payment cycle time  Measure the ROI  Identify areas of improvement and work with our suppliers to address  Reduce time spent on paperwork by suppliers

5

The journey has started…..

Competitiveness Our partners play a role in our level of competitiveness  Innovative ideas from our suppliers  Communicate changes in technology that provide an edge to the Bank  Demand planning, management and projections with input from our suppliers  Collaboration on supply chain management to minimize ineffjciencies/improve TAT

6

The journey has started…..

Value Creation is both ways Vendor Relationship Management T eam  Focused on enhancing relationship with our vendors  Value driven spend  Creation of dedicated helpdesk for suppliers (First Suppliers Support - Firstsupplierssupport@fjrstbanknigeria.com)  T wo-way feedback  Vendor Performance Management  Feedback from internal stakeholders  Contract/SLA Compliance  Quality of goods and services supplied  Feedback from our suppliers on our services via

7

Building Resilience

Suppliers’ practices are synonymous with growth and stability  Business Continuity Planning and Management  Standard code of conduct  Health, safety and stafg welfare  Voice of the Vendor (Periodic Engagement with vendors)  Suppliers ability to withstand market shocks  Guidance on products that improve profjtability

Capital & Currency Concerns Regulatory Concerns

8

2019 and beyond

 Keeping you in business is our goal  Joint growth with our partners  Becoming generational businesses  Another 125 years……

Thank you

August 7th 2019

2019: Annual Engagement & Awareness Session for Key Vendors Topic: Anti-Bribery and Corruption, Disclosure of related parties, Right to Audit, Non-Disclosure Agreement Presentation by the Compliance Department

Our Vision & Mission Statements

2

Our Vision: Our Mission:

To be the clear leader and Nigeria’s bank of fjrst choice To remain true to our name by providing the best fjnancial services possible

Expected Outcomes

Introduction The Compliance Department as a Stakeholder in Vendor Management The Compliance Policies in Vendor Management Regulatory Expectations Conclusion

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Introduction

THIRD PARTY

Vendors Suppliers Agents Contractors Consultants Customers

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First Bank is committed to conducting business with utmost level of integrity, transparency, and compliance with legal, ethical and regulatory standards. Our reputation and success as an organization is built upon this foundation as we strive to maintain our position as a leading organization both locally and internationally. First Bank is committed to working with third party vendors to promote responsible practices throughout our operations. The Bank aims to ensure that all third party vendors/ suppliers acknowledge its values and share its commitment to conduct business in an ethical, legal and socially responsible manner.

The Compliance Department as a Stakeholder in Vendor Management

Third parties present a broad range of risks, including:  Compliance risks such as violations of laws, rules, or regulations or non-compliance with policies or procedures;  Reputation risks such as dissatisfjed customers or violations of laws

• r regulations that lead to public enforcement actions;

 Transaction risks such as problems with service or delivery; and  Operational risks such as losses from failed processes or systems or losses of data that result in privacy issues;  Credit risks such as the inability of a third party to meet its contractual obligations.

www.fjrstbanknigeria.com 5 Risk Management

Compliance Risks Reputationa l Risks Transaction Risks Operational Risks Credit Risks

The Compliance Department of First Bank Nigeria Limited have the oversight of ensuring that the Bank is not exposed to sanctions emanating from non- compliance with established laws, regulations and policies. Hence managing vendor-related Compliance Risks and Reputation Risks is included in our strategic plans.

The Compliance Policies in Vendor Management

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The Anti-Bribery and Corruption Policy The Policy on the Receipt of Gifts and Hospitality from Third Parties The Third Party Code

• f Conduct

The Confmict of Interest and Related Party T ransaction Policy The Whistleblowing Policy

The Anti-Bribery and Corruption Policy

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Facilitation Payments Reciprocal Agreements Donations e.g. Political The Anti-Bribery and Corruption Policy

Bribery can be defjned as ofgering, promising or giving a fjnancial (or other) advantage to another person with the intention of inducing or rewarding that person to act or for having acted in a way which a reasonable person would consider improper in the circumstances and Corruption is any form of abuse of entrusted power for private gain and may include, but is not limited to, bribery. Acts of bribery or corruption are designed to infmuence an individual in the performance of their duty and incline them to act in a way that a reasonable person would consider to be dishonest in the circumstances.

WE DO NOT ENCOURAGE:

Used by businesses or individuals to secure or expedite the performance of a routine or necessary action to which the payer has an entitlement as of right. An exchange of goods or services, where one transfer is contingent upon the other Whilst charitable donations are acceptable, management and employees must ensure that these contributions and sponsorships are not used as a ploy to facilitate a bribe

The Policy on the Receipt of Gifts and Hospitality from Third Parties

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Cash

.

Cash- valued items e.g Prepaid cards; Airtime credit Any gift or entertainment provided in direct exchange for a reciprocal action

WE DO NOT ALLOW:

Any item or entertainment that is illegal or sexually explicit, involves gambling, or would otherwise violate

• ur values or our Standards of Business Conduct

Any item that might present an appearance of impropriety, conflict of interest or undue influence. Anything that may cause embarrassment to FirstBank or damage FirstBank's reputation. Excessive, lavish, or frequent gifts or entertainment Gifts provided during a competitive bid process or contract negotiation.

The Policy on the Receipt of Gifts and Hospitality from Third Parties

GIFTS are defjned as anything of value, including – but not limited to: Loans, cash, favorable terms or discounts on any product or service, services, equipment, prizes, products, transportation, lunch/meals, use of vehicles, vacation or other facilities, stocks or other securities, home improvements, tickets, gift certifjcates, gift cards, discounts except those available to all First Bank stafg, memberships and employment or consulting relationships. It also includes anything given to any employee OR immediate family member /relation of an employee from which the recipient may derive any benefjt.

The Third Party Code of Conduct

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The Third Party Code of Conduct

The Third Party Code of Conduct states the rules, values, ethical principles and vision that Firstbank, at the very minimum, expects from it vendors and third party affjliates.

WE EXPECT:

Third parties must be committed to treating their workers with respect and dignity Third party vendors must not engage in or support discrimination and to adopt a non- discriminating practice that strives to ensure fair treatment Third parties shall not use child labour. The acceptable minimum age for employees is 15 years (see. S.59 of the Labour Act, LFN 2004) Pay all employees a fair compensation, in accordance with national laws and regulations, including overtime hours and all legally mandated benefits. Comply with appropriate working hour requirements as established by national law or relevant collective agreements Suppliers will not use or benefit from, forced or involuntary labour. All employees shall enjoy the freedom of movement during the course of their employment

The Confmict of Interest and Related Party Transaction Policy

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The Conflict of Interest and Related Party Transaction Policy

CONFLICT OF INTEREST refers to situations in which personal, occupational or fjnancial considerations may afgect, or appear to afgect, a Director’s/ stafg members’ objectivity, Judgment or ability to act in the best interests of the Bank. RELATED PARTY TRANSACTION refers to the transfer of resources, services or

• bligations between related parties, regardless of whether a price is charged.

WE EXPECT: New and existing contractors of the Bank are required to disclose their relatedness to any Director or Stafg of the Bank through the VENDOR INFORMATION ON RELATED PARTY INTEREST FORM All vendors are expected to fjll the form and declare any potential/existing confmicts of interest and related party transactions with the Bank. Non- Disclosure = Blacklisting

The Whistleblowing Policy

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The Whistleblowing Policy

WHISTLE-BLOWING is the reporting

• f

alleged unethical conduct

• f

employees, management, directors and other stakeholders by an employee or

• ther

person to appropriate authorities. All employees, stakeholders, and members of the public can raise legitimate concerns, without fear

• f reprisal and are given assurance

that such concerns would be adequately addressed.

OUR WHISTLEBLOWING CHANNELS:

Formal Letter

• Managing Director/Chief Executive Officer (GMD/CEO) of First Bank of Nigeria Limited &

Subsidiaries

• Chief Audit Executive (CAE),
• Chief Compliance Officer
• Group Head, Internal Control and Enhancement Group

Phone Service

• Chief Audit Executive on 08127166777
• Chief Compliance Officer on 09070366415
• Group Head, Internal Control and Enhancement Group on 09070366416
• Chairman, Board Credit Committee on 09070288148
• Chairman, Board Audit Committee on 09070288147

Web Service

• Dedicated whistle blowing e-mail: whistleblowing@firstbanknigeria.com
• Electronically log on to www.firstbanknigeria.com and click on the whistleblowing portal to report

the misconduct.

• E-mail:
• Managing Director/Chief Executive Officer (GMD/CEO) of First Bank of Nigeria Limited &

Subsidiaries

• Chief Audit Executive (CAE),
• Chief Compliance Officer
• Group Head, Internal Control and Enhancement Group

Regulators

• Directly to the CBN on e-mail address: anticorruptionunit@cbn.gov.ng
• We

subject

• ur

Whistleblowing Policy to review annually by external consultants, to ensure that we have an unbiased implementation

• f

the policy

Check our website for the Whistleblowing Policy

FIRSTBANK Expectations

12

The Anti-Bribery and Corruption Policy

DO NOT Offer bribes to our staff ;

• r on our

behalf

The Policy on the Receipt of Gifts and Hospitality from Third Parties

DO NOT OFFER ANY GIFTS OR TIPS OR HOSPITALITY TO OUR STAFF; THE BANK IS YOUR CUSTOMER, NOT THE STAFF

The Third Party Code of Conduct

ENSURE GOOD CONDUCT ALWAYS. WHAT AFFECTS YOU, AFFECTS US.

Conflict of Interest and Related Party Transactions DISCLOSE ALL RELATED TRANSACTIONS. WE WANT YOU TO BE TRANSPARENT The Whistleblowing Policy REPORT POLICY VIOLATIONS. IT IS IN YOUR BEST INTEREST

WE ENCOURAGE TRANSPARENCY AND INTEGRITY

Regulatory Expectations – Due Diligence & 3rd Party Data Processing Contracts

• Third parties to implement reasonable

measures to ensure that principles of the Nigerian Data Protection Regulations 2019 are not violated. Confjdential and trade secrets should not be shared in line with the Non- Disclosure and Confjdentiality Agreements

• Third parties should know that their

reputation can impact our brand, so they should conduct all business with integrity

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Safeguarding the rights of natural persons to data privacy - Personal data shall be collected and processed in accordance with specifjc, legitimate and lawful purpose

FirstBank Information

WE EXPECT:

• Ensure that data usage is strictly for the purpose
• f collection
• Ensure and be able to demonstrate that consent is

freely obtained from customers and relevant clauses are presented in clear and plain language that are easily understandable

• Obtain consent before transferring personal data
• Avoid penalty for breach

ND PR

Minimum Requirements for Onboarding Third Parties with FirstBank

14

For Payment Purposes: We request the same information that is required to open a corporate account to render services. There are no waivers for

• pening accounts without the required documentation.

FirstBank recognizes that the use of Third Parties could create security, AML/CFT and regulatory breaches hence the risks involved must be adequately managed to avoid risk crystallization. At the very minimum, the following due diligence will be conducted:

• a. Background check
• b. Review of the vendor business model
• c. Vendor fjnancial data and cash fmows
• d. Operational review
• e. Compliance to regulatory directives.

Conclusion

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COMPLI ANCE

Encoura ge a Complia nce Culture Maintai n Integrity Report Violatio ns Promot e Sustain ability Avoid Criminal ity Law- Abiding

Partnership in ensuring Compliance will lead to profitable outcomes

PROFITABILI TY