Fair Finance Ghana ESG policy assessment report
This report assesses ESG policies across five Ghanaian banks using international benchmarks. Results show low sustainability integration, particularly regarding climate change and transparency. It recommends adopting global frameworks, extending ESG accountability to lending portfolios, and improving standardised reporting to align the sector with international best practice.
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OVERVIEW
Introduction
In Ghana, financial institutions are increasingly integrating sustainability into their operations, with compliance to the Bank of Ghana’s Sustainable Banking Principles rising from 42.2 per cent in 2021 to 73.6 per cent by March 2025. This report provides a comprehensive assessment of the Environmental, Social, and Governance (ESG) policies of five sampled Ghanaian banks. Using the 2025 Fair Finance Methodology, it evaluates institutional commitments against international standards across eight core themes, including biodiversity, climate change, and human rights.
Assessment results of financial institutions
The assessment indicates a low and uneven integration of ESG principles across the banks. Scoring is based on policy content and the scope of application across investment categories. Bank A exhibited scores of 2.7 for Taxes and 0.9 for Gender equality but recorded 0.0 in most other themes. Bank B showed more advanced commitments with 4.4 in Labour rights and 2.8 in Biodiversity. Bank C achieved 5.3 in Labour rights, while Bank D adjusted its scores following feedback regarding its commitment to IFC Performance Standards.
Thematic findings
Labour rights recorded the highest average score of 2.5, followed by tax responsibility at 2.4. Biodiversity (1.7), human rights (1.3), and gender equality (1.2) showed low-to-moderate engagement. Conversely, climate change emerged as the weakest area with an average score of 0.2, reflecting a critical gap in transition planning. Transparency and accountability (1.0) and corruption (0.7) also performed poorly. Most ESG considerations remain confined to internal operations, with limited accountability for companies benefiting from bank lending.
Discussions
Low performance is attributed to three structural issues: limited adoption of international sustainability standards, weak accountability mechanisms for investees, and inadequate use of standardised reporting frameworks. Many banks lack clear policies extending ESG expectations to corporate borrowers. Consequently, performance in areas like biodiversity and climate change, where impacts are often indirect, remains weak. The findings suggest that scores reflect a lack of alignment with global best practices rather than simple regulatory non-compliance.
Conclusion and recommendations
The report underscores a significant gap between Ghana’s banking sector and global ESG governance. It recommends that banks formally adopt international frameworks, such as the Equator Principles, IFC Performance Standards, and UN Guiding Principles. Banks should extend ESG accountability to corporate credit and project finance. Additionally, regulators are encouraged to incentivise sustainable finance through fiscal measures, such as preferential capital treatment for green assets, and to strengthen guidance on climate risk management, transparency, and human rights.