Rule of Conduct


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 recognised 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 fulfil 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.




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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