Introduction

Finance is not neutral; every loan and investment choice shapes lives, communities, and ecosystems. In Nigeria, a country where climate vulnerability, extractive industries, and governance challenges intersect, the decisions made by financial institutions carry enormous weight. These choices can either accelerate inequality and environmental harm or drive a just and sustainable future. While global expectations for Environmental, Social, and Governance (ESG) standards are rising rapidly, Nigerian banks have largely limited their efforts to meeting domestic regulatory requirements. This report, conducted by Fair Finance Nigeria (FFNG), provides the country’s first systematic review of sustainability and responsible finance policies among leading banks, benchmarking them against more than 400 international standards. The assessment examined how institutions integrate sustainability across eight themes: biodiversity, climate change, corruption, gender equality, human rights, labour rights, taxation, and transparency and accountability. Findings indicate that while progress is visible in areas like labour rights, glaring gaps persist in climate action and tax responsibility.

About the methodology for the first Nigerian bank policy assessment

The assessment was conducted between July and November 2025, utilizing the 2025 Fair Finance Guide (FFG) Methodology. This rigorous framework covers over 422 international sustainability standards and criteria to assess the compliance and reporting of financial institutions. The methodology aims to stimulate a ‘race to the top’ by benchmarking institutions against global best practices in critical areas such as human rights and climate impact. Four major banks were selected for this round based on their market share, customer base, and involvement in Nigeria’s oil and gas sector: Access Bank, Zenith Bank, United Bank for Africa (UBA), and Standard Chartered Nigeria. Access Bank leads the sector with a customer base of over 60 million and assets of USD 27.20 billion. Zenith Bank holds the highest local market capitalization at USD 2.08 billion, while UBA reports over 35 million customers and USD 1.09 billion in market capitalization. Standard Chartered Nigeria, part of a global group, benefits from a parent organisation with USD 37.9 billion in market capitalization.

Key findings

The cross-institutional review reveals that all four financial institutions exhibit performance profiles heavily shaped by Nigeria’s regulatory environment rather than international sustainability leadership. Policy scores cluster in the low-to-medium range, with an overall average performance of 1.7/10. Most sustainability commitments remain general and descriptive, often lacking clear enforcement mechanisms for internal operations or investment portfolios. The highest-performing theme across the banks was labour rights, which achieved an average score of 2.9, followed by corruption at 2.6. In contrast, performance was significantly lower in themes such as taxes, which scored an average of 0.0, and climate change, which averaged 0.9. Transparency and accountability also recorded a poor average of 1.3. Specifically, Standard Chartered achieved the highest overall score of 2.7, followed by Access Bank at 1.7, Zenith Bank at 1.3, and UBA at 1.2. Notably, despite some progress in anti-corruption and labour rights, glaring gaps persist in biodiversity protection and tax responsibility across all assessed institutions.

Discussion of findings

A consistent pattern emerges where banks prioritise sustainability themes mandated by the Central Bank of Nigeria (CBN), such as anti-money laundering and consumer protection. Themes requiring voluntary leadership—including climate change, human rights, and biodiversity—receive limited attention, with disclosures remaining largely generic and internally focused. There is a significant ‘climate gap’, as banks fail to report baselines or year-on-year progress regarding their investment portfolios. Furthermore, banks demonstrate high exposure to sustainability risks in high-impact sectors like oil and gas, mining, and agribusiness, yet most lack sector-specific guidelines or exclusion lists for activities such as coal mining or deforestation. Client-facing sustainability expectations are largely absent from loan covenants and credit-risk reviews. This limited ESG integration into core banking operations leaves institutions exposed to reputational, operational, and financial risks, and represents a missed opportunity to create innovative sustainability-aligned products such as green bonds or gender-lens investing instruments.

Recommendations and conclusion

The report concludes that while the Nigerian banking sector has begun its journey toward responsible banking, it remains constrained by limited transparency and a lack of strategic ESG integration. For Nigerian banks, recommendations include developing standalone sustainability reports published annually and adopting robust, sector-specific policies that define expectations for clients in high-risk industries. Banks should also improve the accessibility of ESG progress reports on their websites and extend ethical standards beyond internal operations to cover investment portfolios while indicating pathways for achieving their ESG roadmaps. For Nigerian financial regulators and government stakeholders, it is suggested that the 2012 Nigerian Sustainability Banking Principles (NSBP) be updated to align more closely with current international standards. Additionally, regulators should encourage banks to strengthen their ethical compliance and sustainability teams to improve engagement with diverse stakeholders, including civil society. Closing these gaps is essential for creating a financial sector that champions equity, accountability, and sustainability for Nigeria’s future.