1. Executive Summary
UBBfh Bank is steadfastly committed to ensuring the continuity of its critical operations, safeguarding stakeholder interests and maintaining financial stability in the face of disruptive incidents. In strict alignment with ISO 22301:2019, we have instituted a comprehensive and resilient Business Continuity Management System (BCMS). This robust framework not only fulfils regulatory obligations but also reinforces trust in our services. Our BCMS encompasses detailed protocols, coordinated crisis management processes and adherence to international best practices to enable swift recovery and operational continuity.
2. Scope of the BCMS
The BCMS is applicable to all UBBfh Bank operations and covers the following areas:
Core Banking Services: Payments, lending, treasury operations and other mission-critical functions. Digital Platforms and IT Infrastructure: Online banking, mobile applications, cybersecurity systems and data centres. Critical Third-Party Dependencies: Cloud service providers, payment networks, fintech partners and other vital vendor relationships. Physical Premises and Personnel: Branch operations, office facilities, and all employees, including remote staff. Supply Chain and Logistics: Essential service providers and external supply networks that support our day-to-day operations. Governance of the BCMS is maintained by the Board of Directors and is seamlessly integrated with our Enterprise Risk Management (ERM), IT disaster recovery and cybersecurity frameworks.
3. Leadership and Governance
3.1 Leadership Commitment
The Board of Directors and Senior Management of UBBfh Bank have established an unequivocal commitment to business continuity. The BCMS policy:
Clearly defines accountability and establishes a culture of resilience across all organisational levels. Ensures the allocation of sufficient resources for BCMS implementation, ongoing testing and continual enhancement. Complies with the central bank’s Operational Resilience Guidelines and other local regulatory requirements [reference local regulations]. Regularly reviews performance metrics, historical downtime reductions and test success rates to inform strategic improvements. 3.2 Roles and Responsibilities
To ensure effective governance and rapid response, the following roles have been delineated:
Business Continuity Manager (BCM): Oversees the complete implementation and maintenance of the BCMS, reporting directly to the Chief Risk Officer. Crisis Management Team (CMT): Mobilised during incidents to coordinate response and recovery efforts, ensuring clear communication with stakeholders. Department Heads: Responsible for embedding BCMS processes into daily operations and ensuring staff are trained and prepared for potential disruptions. Vendor Management Lead: Works with third-party providers to establish continuity obligations and monitor the resilience of external partners. 4. Planning and Risk Management
4.1 Business Impact Analysis (BIA)
Our annual BIA is a critical component of the BCMS and is designed to:
Identify and prioritise critical business functions, such as real-time payment processing and customer data management. Determine Maximum Tolerable Downtime (MTD) and Recovery Time Objectives (RTOs) with precision. Quantify potential financial, operational and reputational impacts, thereby guiding strategic recovery and mitigation efforts. Inform resource allocation by highlighting dependencies and vulnerability hotspots. 4.2 Risk Assessment
UBBfh Bank’s risk assessments are executed in strict accordance with ISO 31000. The process includes:
Evaluation of internal and external threats, including cyberattacks, natural disasters, third-party failures and emerging risks. Prioritisation of risks by analysing both likelihood and impact, which informs our investment in risk controls. Deployment of robust measures such as geographically dispersed data centres, encrypted backups, failover systems and vendor diversification. Regular review and update of risk registers in line with a dynamically changing threat landscape. 4.3 Business Continuity Strategies
Our continuity strategies are both multi-layered and adaptable:
IT Resilience: Implementation of multi-cloud redundancy, encrypted data backups, and rapid failover systems to ensure digital service continuity. Workforce Continuity: Adoption of remote work protocols, regular cross-training initiatives and succession planning to mitigate personnel-related disruptions. Third-Party Risk Management: Rigorous due diligence, stringent contractual continuity obligations and continuous monitoring of critical vendors. Crisis Communication: Establishment of clear internal and external communication channels to ensure timely and accurate information dissemination during disruptions. 5. BCMS Implementation and Support
5.1 Resource Allocation
UBBfh Bank is dedicated to ensuring that our BCMS is well-resourced and supported through:
Investment in advanced BCMS software tools, such as incident management platforms, to facilitate rapid detection and response. Comprehensive staff training programmes and regular awareness sessions, ensuring that all personnel understand their roles in a crisis. Significant capital expenditure in infrastructure resilience, including backup generators, satellite communications and secure data centres. 5.2 Communication Protocols
A well-defined communication strategy underpins our operational resilience:
Internal Communication: Utilisation of secure channels (e.g. encrypted messaging, crisis hotlines) to facilitate timely escalation and decision-making. External Communication: Structured protocols for regulatory reporting, customer notifications, and media management, ensuring clarity and consistency in messaging. Stakeholder Engagement: Regular updates to investors, partners and regulatory bodies, reinforcing transparency and trust. 5.3 Documentation
Meticulous documentation is maintained to support our BCMS, including:
Business Continuity Plan (BCP): Detailed procedures and contingency plans. Incident Response Playbooks: Step-by-step guides for a range of potential disruption scenarios. Recovery Procedures: Protocols for restoring critical systems and operations, with clear timelines and responsibilities. Training Records and Audit Reports: Evidence of ongoing training, testing and compliance reviews. 6. Operational Execution
6.1 Incident Response
UBBfh Bank follows a rigorous incident response process to ensure swift and coordinated action:
Detection: Continuous monitoring through our 24/7 Security Operations Centre (SOC) to promptly identify incidents. Assessment: The Crisis Management Team (CMT) evaluates incident severity based on pre-established criteria, including impact on customers and financial loss. Activation: Immediate execution of the BCP, with prioritisation of customer-facing services and mission-critical operations. Communication: Immediate and coordinated communication with internal teams and external stakeholders to ensure clarity and rapid resolution. 6.2 Recovery and Restoration
Recovery plans are designed for rapid restoration of operations:
IT Systems: A Recovery Time Objective (RTO) of ≤4 hours for core banking applications is maintained through redundant systems and failover protocols. Physical Sites: Designated alternate sites are available, with capabilities to assume critical operations within 12 hours. Vendor Coordination: Established protocols ensure that third-party services are restored in a timely manner, minimising operational disruption. 6.3 Testing and Exercises
To validate our BCMS and identify areas for improvement, UBBfh Bank conducts regular testing exercises:
Full-Scale Simulations: Annual drills that simulate scenarios such as cyberattacks and pandemics to test the full spectrum of our response capabilities. Quarterly Tabletop Exercises: Involving department heads and third-party vendors to ensure readiness and effective collaboration. Post-Test Reviews: Detailed analyses following exercises to update plans, close gaps and implement lessons learned. 7. Performance Evaluation and Improvement
7.1 Monitoring and Audits
Continuous evaluation of our BCMS is achieved through:
Internal Audits: Conducted biannually to verify compliance with ISO 22301 and to identify improvement opportunities. Management Reviews: Quarterly presentations to the Board, highlighting performance metrics, test outcomes and risk mitigation progress. Key Performance Indicators (KPIs): Regular monitoring of metrics such as downtime reduction, test success rates and incident response times. 7.2 Continual Improvement
UBBfh Bank embraces a culture of continuous improvement utilising the PDCA (Plan-Do-Check-Act) cycle:
Systematic incorporation of lessons learned from real incidents, exercises, and audits. Regular updating of risk assessments, BIAs and continuity strategies in line with emerging threats. Benchmarking against industry standards, including FFIEC and Basel III guidelines, to remain at the forefront of operational resilience. 8. Regulatory Compliance
UBBfh Bank’s BCMS is designed to meet and exceed the regulatory expectations of the Bank of Ghana and other relevant authorities:
Alignment with the directives outlined in the [Central Bank Name]’s Operational Resilience Directive [reference specific clauses]. Stringent adherence to anti-financial crime measures, ensuring uninterrupted transaction monitoring and robust fraud prevention controls. Comprehensive compliance with data protection laws, including GDPR and local data sovereignty rules, thereby safeguarding customer information and maintaining trust. Ongoing dialogue with regulators to ensure that our processes reflect both current best practices and emerging regulatory developments. 9. Conclusion
UBBfh Bank’s ISO 22301-certified BCMS is a testament to our unwavering commitment to operational resilience. Our meticulous framework, from detailed risk assessments to rapid incident response and recovery protocols, ensures that we continue to deliver essential services under all circumstances. We remain open to further dialogue with regulators to provide deeper insights into our processes and to collaborate on enhancing systemic financial stability.
Attachments
Annex B: Latest BIA and Risk Assessment Reports. Annex C: Testing Schedules and Results.
