Our code of ethics


This standard code of ethics provides professional ethics guidelines to be followed by executives or employees of financial investment companies in the performance of their duties. Financial investment companies can formulate and implement a code of professional ethics that is suitable to the characteristic of their own company using this code of ethics as a standard. Each member shall comply with the following fundamental principles:

(a) Integrity – to be straightforward and honest in all professional and business relationships.

(b) Objectivity– to not allow bias, conflict of interest or undue influence of others to override professional or business judgments.

(c) Professional Competence and Due Care– to maintain professional knowledge and skill at the level required to ensure that a client or employer receives competent professional services based on current developments in practice, legislation and act diligently and in accordance with applicable professional standards.

(d) Confidentiality–to respect the confidentiality of information acquired as a result of professional and business relationships and, therefore, not disclose any such information

to third parties without proper and specific authority, unless there is a legal or professional right or duty to disclose, nor use the information for the personal advantage of the professional or third parties.

(e) Professional Behavior– to comply with relevant laws and regulations and avoid any action that discredits the profession and industry.



1. Purpose

The purpose of this code of ethics is to ensure that the executives and employees of Members of the GSIA faithfully implement their responsibilities and duties by cultivating proper ethics in order to contribute to the stable growth of the capital market and the development of the national economy by protecting investors.

2. Scope of Application

This code of ethics is applicable to all members of the GSIA and their employees.

Every member of the GSIA engaged in providing financial investment services shall comply with this code of ethics for all customers, including potential customers who have not signed any contract with them.



1. Good Faith

Executives and employees of GSIA members shall make honesty and trust their most important value, and shall perform their duties fairly based on moral ethics.

2. Duty of Faithfulness

Executives and employees of GSIA members shall do their utmost to maintain their expertise by taking pride in their role as financial service advisors and providers, while faithfully performing their duties for the continuous growth of their company and the GSIA and the development of the Securities Industry in Ghana.

3. Compliance with Laws

Executives and employees of GSIA members shall, when performing their duties, fully understand and comply with all the laws and regulations related to maintaining the integrity of the capital market.

4. Principles of Customer First

Executives and employees of GSIA members shall operate with the understanding that customers are the basis and reason for their company’s existence, and they shall always act in the customer’s interest.




1. Maintenance of Independence and Objectivity

Executives and employees of GSIA members shall not perform any activities that are influenced by their own or a third party’s interests. They shall take reasonable care to maintain their independence and objectivity.

2. Prevention of Conflicts of Interest

Executives and employees of GSIA members shall do their best to prevent conflicts of interest between the company, shareholders, or customers, and in cases where there is a conflict of interests, it shall be managed in accordance with due process of law.

3. Prohibition of Unfair Transactions

Executives and employees of GSIA members shall not engage in any unfair trade practices including the use of undisclosed important information or manipulating the market, and also they shall not participate in unfair transactions that can be identified through the exercise of reasonable care.

4. Prohibition of Accepting Money and Valuables

Executives and employees of GSIA members shall not request gifts, etc., or accept entertainment, money or other objects of value, etc. that are in violation of the social commercial code, in return for performing their duties or in connection to their duties.

5. Reporting of Practices in Violation

Executives or employees of GSIA members shall, in the case where they have identified a violation of the law or the code of ethics, or recognized the possibility of such a violation while performing their duties, immediately report such a violation to their superiors or the relevant department.

6. Development of Expertise

Executives or employees of GSIA members shall devote themselves to remaining well informed of the theory and work needed for the performance of their duties, and they shall make best efforts to maintain and improve their expertise to fulfill the duties they are required to perform.

7. Mutual Respect

Executives or employees of GSIA members shall respect and be courteous to their colleagues, and they shall establish relationships based on mutual trust through fair competition.


1. Devotion to Duties

Executives or employees of GSIA members shall be devoted to their duties and shall receive prior approval before undertaking additional duties or activities that may affect the performance of their duties for the company. However, in the case of an event of force majeure, an ex post facto report shall be reported immediately.

2. Protection of Information

Executives or employees of GSIA members shall not divulge important information related to their duties or the company. The maintenance and management of such information shall be in accordance with the due process of the law.

3. Maintenance of Dignity

Executives or employees of GSIA members shall not perform any conduct that defames the social trust or the company’s dignity through their action.

4. Prohibition of Illegal Use of Company Properties

Executives or employees of GSIA members shall not illegally use the company’s properties or use their position for their own personal interest.

5. Supervision and Management

The management of GSIA members shall provide appropriate supervision and management so that those under their command and supervision are not in violation of the relevant laws, etc. in connection with the performance of their duties.

6. Duty after the Expiration of the Employment Contract

In the case where executives or employees of GSIA members retires from the company, appropriate follow-up measures shall be taken, and for a considerable period of time after retirement, such employees shall not engage in conduct that damages the interests of the company they have retired from


1. Priority on Customer Interests

Executives or employees of GSIA members shall make the interests of the customers their first priority. One’s own interest or a third party’s interest shall not be put before the interests of the customers.

2. Duty of Due Diligence

Executives or employees of GSIA members shall, when performing their duties, do their best to pay attention as an expert to ensure the maximum returns for customers and the integrity of the market.

3. Maintenance of Suitability

Executives or employees of GSIA members shall, when recommending investments to customers, induce suitable investments by clearly identifying the customer’s investment purpose, the customer’s investment experience, and the level of risks that the customer is willing to take, etc.

4. Maintenance of Fairness

Executives or employees of GSIA members shall not discriminate between customers without justifiable reasons when performing their duties

5. Duty of Notification and Explanation

Executives or employees of GSIA members shall, when trading with customers, give in-depth notification about any conditions that are likely to have an important effect on such trading. Important information shall also be explained to ensure the customers understand.

6. Provision of Reasonable Grounds

Executives or employees of GSIA members shall, when providing investment information or recommending investment to customers, give data based on precise investigation and analysis based on reasonable and sufficient grounds.

7. Duty of Accurate Expression

Executives or employees of GSIA members shall, when providing investment information or recommending investment to customers, clearly differentiate personal opinions from objective facts, and shall not provide conclusive judgment on uncertain matters, including expressions that may mislead customers as a guarantee of investment returns.

8. Duty of Reporting and Recording

The results of the duties delegated by the customers to executives or employees of GSIA members shall be reported to the customers without delay. Records and evidences related to performing the duties shall be stored according to due process.

9. Prohibition of Divulging and Illegally Using Customer Information

Executives or employees of GSIA members shall not divulge customer information, or illegally use it for their own or a third party’s interests.



A code of conduct is a set of rules outlining the responsibilities of or proper practices for an individual, party or organization. In its 2007 International Good Practice Guidance, Defining and Developing an Effective Code of Conduct for Organizations, the International Federation of Accountants provided the following working definition: “Principles, values, standards, or rules of behavior that guide the decisions, procedures and systems of an organization in a way that (a) contributes to the welfare of its key stakeholders, and (b) respects the rights of all constituents affected by its operations.”

1. For the purposes of GSIA’s Code of Professional Conduct (the Code), Members shall include, as applicable, any of their employees and contractors.

2. Members shall conduct their activities in a professional and competent manner with respect for the public interest, maintaining the privacy and confidentiality in their dealings, and shall at all times act with integrity in dealing with clients, employees or sub-contractors, past and present, with their fellow Members and with the general public. The objective of the Code is for Members to adopt best practice industry standards.

3. Members shall not intentionally disseminate false or misleading information, whether written, spoken or implied, nor engage in false, misleading or deceptive conduct or otherwise bring the security industry into disrepute. Members have a duty to maintain truth, accuracy and good taste in advertising and sales promotion.

4. Members shall not represent conflicting or competing interests except with the express consent of those concerned given only after full disclosure of the facts to all interested parties.

5. Members shall refrain from knowingly associating with any business organization, which uses improper or illegal methods for obtaining business.

6. Members shall not intentionally injure the professional reputation or practice of another Member.

7. Members shall comply with all applicable legislation covering security providers and in particular statutory obligations, including but not limited to matters relating to securities laws, health and safety and workplace relations laws.

8. GSIA is to be informed when the Member’s attention has been drawn to any breach by that Member of the Code.

9. Members shall help to improve the body of knowledge of the profession by exchanging information and experience with fellow Members, participating in industry related programs designed to raise the standard of service delivery, and by applying their special skill and training for the benefit of others.

10. Members shall refrain from using their relationship with the Association in such a manner as to state or imply an official accreditation or approval beyond the scope of membership of the Association and its objectives, rules and policies.

11. Members shall cooperate with fellow Members in upholding and enforcing the GSIA Code of Professional Conduct

12. Members shall have in place procedures to deal appropriately and promptly with complaints about the provision of its services and actively engage in the resolution of complaints raised via GSIA’s dispute resolution policy and procedure.

13. Members shall maintain appropriate and accurate records in accordance with all relevant statutory requirements.

14. Where an alleged breach of this Code is appropriately brought to the attention of GSIA, then GSIA will in the first instance raise this matter in writing with the Member. GSIA will provide the Member with the opportunity to take remedial action, if that is appropriate under the circumstances, or where remedial action should have been but has not been carried out by the Member, then GSIA is to inform the Member that it will take the appropriate disciplinary action by way of a show cause notice why their membership should not now be cancelled.





On Friday November 8, 2019 the (SEC) revoked the licences of 53 fund management companies. The action was meant to protect investor interest and the integrity of the capital market. We welcome any moves that will shore up the industry and ultimately boost investor confidence. We wish, however, to state the following:

There is no need for panic withdrawals by investors. The industry is no worse off today than it was before the action by the SEC. Twenty One (21) of the firms whose licences had been revoked were already not operational and several of the 32 who were operating were already facing serious governance, operational and liquidity challenges. There are several robust fund management firms that are liquid and operating with healthy balance sheets and we are confident that these will continue providing solid services to the investing public.

The Ministry of Finance (MOF), SEC and Bank of Ghana (BOG) must urgently support the investment industry by pushing the Receivers of failed Savings and Loans (S&Ls), Finance Houses and Microfinance firms (MFIs) to pay liabilities to Fund Management firms with validated exposures. Poor governance and ethics played a part in this industry’s current challenges but the banking sector clean-up was the final trigger causing the liquidity challenges that some firms face. Piecemeal pay-outs for validated exposures exacerbate these liquidity challenges and given that pronouncements have been made that no depositors will lose their funds, it is important that validated claims by Fund Managers are immediately honoured.

The SEC must provide clarity on the path forward for investors whose monies were with collapsed firms. This will reduce investor panic and help to forestall a run on the industry. There must also be a clearly spelt out process for firms whose licences have been revoked and who feel they may have a genuine case for review.

The investment industry is the understated complement to the banking sector. Its average growth – 69.5% per annum over the past decade and its size (Ghs 40 billion) are clear pointers to its importance to the broader economy. In order for it to continue playing its intermediation role in the economy it will need a better resourced and engaged regulator, a well-informed investing public and robust, well governed firms that act in the interest of clients.

We wish to assure the investing public that the GSIA will engage with all key stakeholders in order to promote a healthy and vibrant industry that creates wealth for all.

Thank you.

Executive Secretary
Issued on behalf of the Governing Council


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