Compliance Management Policy

The Board and Executive Management of Union Bank of Nigeria, with Head Office at No 36 Marina, Lagos Island, Lagos, is committed to conducting business with the highest standards of integrity, transparency, and accountability. Our Compliance Management System (CMS) is designed inline with global best practices, including ISO37301, to ensure we consistently meet our legal and regulatory obligation.

We operate in full compliance with all applicable laws and regulations, including those issued by the Central Bank of Nigeria (CBN) and othe rrelevant authorities.We continuously monitor regulatory changes and adapt our processes to remain compliant at all times.

We take a zero-tolerance approach to financial crime.Our robust Anti-Money
Laundering,Combating Financing of Terrorism, and Counter-Proliferation Financing (AML/CFT/CPF) framework enables us to prevent, detect, and report suspicious activities.

Our approach includes:
• Verifying customer identities through Know Your Customer(KYC) processes
• Conducting Customer Due Diligence (CDD) and Enhanced Due Diligence (EDD) where necessary.
• Monitoring transactions to identify unusual or suspicious behaviour
• Reporting suspicious transactions to the appropriate regulatory authorities
• Screening against applicable sanctions lists

Our Board of Directors and Executive Management provide strong oversight of our compliance framework. A dedicated Compliance Function ensures that policies, procedures, and controls are effectively implemented across the Bank.We recruit and engage qualified  personnel with no history of regulatory breaches or criminal conduct, capable of carrying out operations professionally and ethically.

We equip our employees with the knowledge and tools they need to uphold our compliance standards through ongoing training and awareness programs.
We promote a culture where employees, customers, and stakeholders can safely raise concerns. Reports can be made through secure and confidential channels,and we strictly prohibit retaliation against anyone who speaks up in good faith.

We regularly review and enhance our compliance systems to ensure they remain effective, responsive, and aligned with evolving regulatory expectations and global standards.
Compliance Policies shall be reviewed periodically to reflect our commitment to enhancing our compliance culture.

The following Compliance policies are to be complied with by all relevant parties (customers, suppliers, regulators, staff, etc):
• Compliance Management System Policy
• Anti-Money Laundering,Combating Financing of Terrorism, and Countering
Proliferation Financing (AML/CFT/CPF) Policy
• Know Your Customer (KYC) Policy
• AntiBribery & Corruption (AB&C) Policy
• Whistle Blowing Policy
• Compliance Charter
• BVN Operations & Watchlist Policy
• Compliance Risk Policy
• Policy Framework on Treatment of Suspicious Transactions on ML/TF/PF
• Policy onTargeted Financial Sanctions onTerrorism and Terrorism Financing
• Policy on Targeted Financial Sanctions on Proliferation Financing

Copies of these compliance policies may be made available for review upon formal request.
To effectively monitor and track our compliance performance, we have established defined compliance objectives.The compliance objectives were derived from the Union Bank Strategic Blueprint for 2026–2030. Union Bank defined the strategic pillars, imperatives and the critical enablers to pursue our aspiration,which we mapped to establish compliance objectives:
• Objective1: Enhance the Bank’s Compliance culture by achieving at least 90% active participation of all employees in all compliance-related activities outlined for the year.
• Objective 2: Ensure 0% Compliance sanctions to maintain business profit margins for the year.

We encourage all stakeholders to support adherence to our compliance policies, enabling us to achieve our compliance objectives and uphold Union Bank’s ethical standards.
For further information or to report a concern, please do not hesitate to contact our Compliance Team via our whistle blowing and official channels.