corporate governance of indian banks

INTERNATIONAL CORPORATE GOVERNANCE 2012

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INTERNATIONAL CORPORATE GOVERNANCE

CORPORATE GOVERNANCE PRACTICES OF

INDIAN BANKS

HIMANSHU VERMA-S116780

ANKIT DOKANIA-S116300

PULKIT KHARE-S116390


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ABSTRACT

In banking parlance, the Corporate Governance refers to conducting the affairs of a banking

organisation in a manner that gives a fair deal to all the stake holders i.e. shareholders, bank

customers, regulatory authority, employees and society at large.

Poor corporate governance of banks has increasingly been acknowledged as an important

cause of the recent financial crisis. In India, even though we largely escaped the financial

crisis, banking industry in India needs to introspect on its own shortcomings and loose

practices. Further, we need to analyse was it the strong regulatory environment or the

strong accountability, transparency and ethics that made Indian banks tide over the crisis.

In India, banking industry is largely dominated by the public sector. This means they are not

only competing with themselves but also other major private players in the banking system

as well as in financial services system. These may include Financial Institutions, Mutual

Funds and other intermediaries, in a new environment of liberalization and globalization.

Also, the penetration level of banking sector in India is very less when compared to the fast

paced development India has witnessed in recent years, which makes their role even more

important.

Further, with restrictive support available from the Govt. for further capitalization of banks,

many banks may have to go for public issues, leading to transformation of ownership.

Also, with FDI norms for private sector banks being liberalized, corporate governance

practices assumes immense importance from the purview of foreign investors.

The role of banks is to mobilize and allocate society’s savings. Especially in developing

countries like India, banks can be very important source of external financing for firms. Also,

banks exert corporate governance over firms, especially small firms that have no direct

access to financial markets. Banks’ corporate governance gets reflected in corporate

governance of firms they lend to.

Thus, our aim will be to analyze corporate governance practices of Indian banks from above

viewpoints.


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OBJECTIVE

Through this paper we seek to understand the:

a) Corporate Governance of the banking industry in general

b) How banks are different from the business organizations

c) Analyze the Indian Banking Industry with respect to the Corporate Governance

framework

Corporate Governance of Banks: Its Genesis and As to Why is it Important?

Corporate governance refers to the set of systems, principles and processes by which a

company is governed. They provide the guidelines as to how the company can be directed

or controlled such that it can fulfil its goals and objectives in a manner that adds to the value

of the company and is also beneficial for all stakeholders in the long term.

Stakeholders in this case would include everyone ranging from the board of directors,

management, shareholders to customers, employees and society. The management of the

company hence assumes the role of a trustee for all the others. An important theme of

discussions concerning corporate governance is the nature and extent of accountability of

decision makers inside the corporation, and mechanisms that try to decrease the principal –

agent problem. The failure of high profile companies such as Enron, WorldCom and

Parmalat is a clear lesson of the damage poor corporate governance can inflict.

The seeds of modern corporate governance were probably sown by the Watergate scandal

in the USA. Subsequent investigations by US regulatory and legislative bodies highlighted

regulatory failures that had allowed several major corporations to make illegal political

contributions and bribe government officials. While these developments in the US

stimulated debate in the UK, a spate of scandals and collapses in that country in the late

1980s and early 1990s led shareholders and banks to worry about their investments. Several

companies in UK which saw explosive growth in earnings in the ’80s ended the decade in a


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memorably disastrous manner. Importantly, such spectacular corporate failures arose

primarily out of poorly managed business practices.

This debate was driven partly by the subsequent enquiries into corporate governance (most

notably the Cadbury Report) and partly by extensive changes in corporate structure. In May

1991, the London Stock Exchange set up a Committee under the chairmanship of Sir Arian

Cadbury to help raise the standards of corporate governance and the level of confidence in

financial reporting and auditing by setting out clearly what it sees as the respective

responsibilities of those involved and what it believes is expected of them. The Committee

investigated accountability of the Board of Directors to shareholders and to the society. It

submitted its report and the associated ‘code of best practices’ in December 1992 wherein

it spelt out the methods of governance needed to achieve a balance between the essential

powers of the Board of Directors and their proper accountability. Being a pioneering report

on corporate governance, it would perhaps be in order to make a brief reference to its

recommendations which are in the nature of guidelines relating to, among other things, the

Board of Directors and Reporting & Control.

The Cadbury Report stipulated that the Board of Directors should meet regularly, retain full

and effective control over the company and monitor the executive management. There

should be a clearly accepted division of responsibilities at the head of the company which

will ensure balance of power and authority so that no individual has unfettered powers of

decision. The Board should have a formal schedule of matters specifically reserved to it for

decisions to ensure that the direction and control of the company is firmly in its hands.

There should also be an agreed procedure for Directors in the furtherance of their duties to

take independent professional advice.

The Cadbury Report generated a lot of interest in India. The issue of corporate governance

was studied in depth and dealt with by the Confederation of Indian Industries (CII),

Associated Chamber of Commerce and Industry (ASSOCHAM) and Securities and Exchange

Board of India (SEBI). These studies reinforced the Cadbury Report’s focus on the crucial

role of the Board and the need for it to observe a Code of Best Practices.


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How Banks are different from other Businesses

Good Corporate Governance Practises of banks is different from other corporates in

important respects, and that makes corporate governance of banks not only different but

also critical. A sound banking system forms the backbone of a sound economy and a

healthy economy. Sound Corporate Governance practises are of utmost importance

especially for emerging market economies because

• Banks have an overwhelmingly dominant position for an economy’s financial

systems, and are extremely important engines of economic growth.

• As financial markets are usually underdeveloped, banks in developing economies are

typically the most important source of finance for the majority of firms.

• Banks in developing countries are usually the main depository for the economy’s

savings.

• Fourth, many developing economies have recently liberalised their banking systems

through privatisation/disinvestments and have reduced the role of economic

regulation. Consequently, managers of banks in these economies have obtained

greater freedom in how they run their banks.

• Bank assets are unusually opaque, and lack transparency as well as liquidity. This

condition arises due to the fact that most bank loans, unlike other products and

services are usually customised and privately negotiated.

• There is contagion effect resulting from the instability of one bank, which would

affect a class of banks or even the entire financial system and the economy. For

example the downfall of the famous U.S Investment Bank, Lehman Brothers, brought

the entire world economy on the brink of recession and added fuel to the 2008 US

recession.

• Given the centrality of banks to modern financial systems and the macro economy,

the larger ones become systemically important. That raises a moral hazard issue

since systemically important banks will then indulge in excessive risk in the full

knowledge that all the gains will be theirs; and should the risks blow up, the


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government or the central bank will bail them out and thereby the losses can be

socialized.

• Having collectively experienced the biggest financial crisis of our generation over the

last three years, we all know that these risks and vulnerabilities of the financial

system are all highly probable real world eventualities.

INDIAN BANKING INDUSTRY

The Indian Banking industry, which is governed by the Banking Regulation Act of India, 1949

can be broadly classified into two major categories, non-scheduled banks and scheduled

banks. The apex decision making body in the Indian Banking is the Reserve Bank of India.

Scheduled banks comprise the commercial banks and the co-operative banks. In terms of

ownership, commercial banks can be further grouped into nationalized banks, the State

Bank of India and its group banks, regional rural banks and private sector banks (the old/

new domestic and foreign). These banks have over 67,000 branches spread across the

country. Further details about the structure of Indian Banking industry can be found in

Annexure-1.

The first phase of financial reforms began in India in 1969 when 14 major banks were

nationalized and resulted in a shift from Class banking to Mass banking. This in turn resulted

in a significant growth in the geographical coverage of banks.

Every bank had to earmark a minimum percentage of their loan portfolio to sectors

identified as “priority sectors”. The manufacturing sector also grew during the 1970s in

protected environs and the banking sector was a critical source. The next wave of reforms

saw the nationalization of 6 more commercial banks in 1980.

After the second phase of financial sector reforms and economic liberalization of the sector

in 1991, the Public Sector Banks (PSB) found it extremely difficult to compete with the new

private sector banks and the foreign banks. The new private sector banks first made their

appearance after the guidelines permitting them were issued in January 1993. Eight new

private sector banks are presently in operation. These banks due to their late start have

access to state-of-the-art technology, which in turn helps them to save on manpower costs

and provide better services.


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Reserve Bank of India has ensured that the transparency and accounting standards in India

have been enhanced to align with international best practices. It has followed a three

pronged strategy:

• Off-site surveillance - monitoring the movement of assets, its impact on capital

adequacy and overall efficiency and adequacy of managerial practices in bank.

• Peer Group Comparison – Brings out the periodic date on critical ratios to maintain

peer pressure for better performance and governance.

• Prompt corrective action policy – Trigger points as capital adequacy ratio, Non-

Performing Assets (NPA) and Return on Assets (ROA) as proxies for asset quality and

profitability.

Corporate Governance – Importance in Indian Context

Sound corporate governance becomes all the more important in the Indian context for the

following reasons:

• A lot of new multinational banks are coming to India in the backdrop of the

opportunities presented by the growth of the economy. There is a general tendency

by the MNC’s to exploit the loopholes in the system if the corporate governance laws

are not stringent.

• Percentage of shareholding by government is 68%-70% in public sector banks, so

due to this high ownership, sometimes agency problems may arise (Annexure-1)

• With the increased needs for capital and limited help from the government has led

many banks to go for public issue, which has led to change in ownership.

• With FDI norms for private banks being liberalised, corporate governance practices

has assumed immense importance from the purview of foreign investors.

• There has been a spur in the investment activities in India, due to which there has

been a steep rise in the need for capital by Indian firms.The lending pattern by the

banks is a reflection of the corporate governance prevalent.

• The penetration of the banking system in the rural areas where the majority of India

lives is still very low. Micro financing Institutions, NBFC (Non Banking Financial


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Corporations) and Cooperative Banks have been instrumental in bridging the

growing demand for capital and its supply. These banks have come under a lot of flak

lately because of their lack of transparency and hence special corporate governance

practises need to be formulated for these kinds of institutions.

Evolution of Corporate Governance of Banks in India

The initiative to initiate corporate governance of Indian banks dates back to 2001, when in

March, an advisory group on Corporate Governance examined the state of corporate

governance in Indian banks. The group under chairmanship of Dr. R.H.Patil made

recommendations to bring the corporate governance practices in line with the best global

practices. The first formal policy initiative with respect to corporate governance of banks in

India was made by Dr. Bimal Jalan in the mid-term review of Monetary and credit policy in

October, 2001. Further, a Consultative group was formed under Dr. A. S. Ganguly to

strengthen the internal supervisory role of the boards.

Now, as we have seen, the level of opaqueness and the relatively greater role of

government and central bank in their functioning set the banking sector apart from other

businesses. This is to this effect that Reserve Bank of India started the process to strengthen

the corporate governance in Indian banking sector.

The current regulatory framework ensures that there is uniform treatment meted out to

public and private banks in terms of prudential norms. Prudential regulations are

regulations of deposit-taking institutions like banks and supervision of the conduct of these

institutions and set down requirements that limit their risk-taking. These requirements can

be in the form of maintaining a stipulated Tier I Capital or a minimum Capital Adequacy

Ratio etc.

This market orientation of governance disciplining in banking has been accompanied by a

stronger disclosure norms and stress on periodic RBI surveillance. From 1994, the Board for

Financial Supervision (BFS) inspects and monitors banks using the “CAMELS” (Capital

adequacy, Asset quality, Management, Earnings, Liquidity and Systems and controls)

approach. Audit committees in banks have been stipulated since 1995.

Greater independence of public sector banks has also been a key feature of the reforms.

Nominee directors – from government as well as RBIs – are being gradually phased off with


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a stress on Boards being more often elected than “appointed from above”. There is

increasing emphasis on greater professional representation on bank boards with the

expectation that the boards will have the authority and competence to properly manage the

banks within the broad prudential norms set by RBI. Rules like non-lending to companies

who have one or more of a bank’s directors on their boards are being softened or removed

altogether, thus allowing for “related party” transactions for banks. The need for

professional advice in the election of executive directors is increasingly realized.

In the pre-reform era, there were very few regulatory guidelines governing corporate

governance of banks. This was reflective of the dominance of public sector banks and

relatively few private banks. That scenario changed after the reforms in 1991 when public

sector banks saw a dilution of government shareholding and a larger number of private

sector banks came on the scene.

The competition brought in by the entry of new private sector banks and their growing

market share forced banks across board to pay greater attention to customer service. As

customers were now able to vote with their feet, the quality of customer service became an

important variable in protecting, and the increasing, market share.

Post-reform, banking regulation shifted from being prescriptive to being prudential. This

implied a shift in balance away from regulation and towards corporate governance. Banks

now had greater freedom and flexibility to draw up their own business plans and

implementation strategies consistent with their comparative advantage. The boards of

banks had to assume the primary responsibility for overseeing this. This required directors

to be more knowledgeable and aware and also exercise informed judgement on the various

strategy and policy choices.

Two reform measures pertaining to public sector banks –

• Entry of institutional and retail shareholders and

• Listing on stock exchanges


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-brought about marked changes in their corporate governance standards. Directors

representing private shareholders brought new perspectives to board deliberations, and the

interests of private shareholders began to have an impact on strategic decisions. On top of

this, the listing requirements of SEBI enhanced the standards of disclosure and

transparency.

To enable them to face the growing competition, public sector banks were accorded larger

autonomy. They could now decide on virtually the entire gamut of human resources issues,

and subject to prevailing regulation, were free to undertake acquisition of businesses, close

or merge unviable branches, open overseas offices, set up subsidiaries, take up new lines of

business or exit existing ones, all without any need for prior approval from the Government.

All this meant that greater autonomy to the boards of public sector banks came with bigger

responsibility.

A series of structural reforms raised the profile and importance of corporate governance in

banks. The ‘structural’ reform measures included mandating a higher proportion of

independent directors on the boards; inducting board members with diverse sets of skills

and expertise; and setting up of board committees for key functions like risk management,

compensation, investor grievances redressal and nomination of directors. Structural reforms

were furthered by the implementation of the Ganguly Committee recommendations

relating to the role and responsibilities of the boards of directors, training facilities for

directors, and most importantly, application of ‘fit and proper’ norms for directors.

Basel Norms and their relation to Corporate Governance

Basel committee is a committee of banking supervisory authorities, established by the

Central Bank Governors of the G10 developed countries in 1975. The Committee in 1988

introduced the Concept of Capital Adequacy framework, known as Basel Capital Accord. As

per Basel committee Report 1999, Banks have to display the exemplary of corporate

governance practices in their financial performance, transparency in the balance sheets and

compliance with other norms laid down by section 49 of corporate governance rules.


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Basel II uses a "three pillars" concept –

(1) Minimum Capital Requirements (addressing risk) - deals with maintenance of regulatory

capital calculated for three major components of risk that a bank faces: credit

risk, operational risk, and market risk.

(2) Supervisory review - Supervisory review process has been introduced to ensure not only

that banks have adequate capital to support all the risks, but also to encourage them to

develop and use better risk management techniques in monitoring and managing their risks.

(3) Market discipline - Market discipline imposes strong incentives to banks to conduct their

business in a safe, sound and effective manner. It is proposed to be effected through a

series of disclosure requirements on capital, risk exposure etc. so that market participants

can assess a bank’s capital adequacy.

Basel II proposals, especially the second and third pillars, underscore the interaction

between sound risk management practices and corporate good governance. The Basel

Committee’s document, “Principles for enhancing corporate governance”, sets out best

practices for banking organisations. The practices are:

• The board has overall responsibility for the bank, including approving and overseeing

the implementation of the overall risk strategy, bank’s policies for risk management,

compliance and bank’s strategic objectives, internal control system, compensation

system etc.

• The board’s qualifications, in terms of adequate knowledge and experience, relevant

to each of the material financial activities the bank intends to pursue to enable

effective governance and oversight of the bank

• The banks need to have an effective internal control systems and a risk management

function to identify, monitor and manage risks on an ongoing firm-wide and

individual entity basis


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• The banks need to have an independent risk management function, including a chief

risk officer or equivalent with sufficient authority, stature, independence, resources

and access to the board

• The board should actively oversee the compensation system’s design and operation,

and should monitor and review the careful alignment of employee compensation

with prudent risk-taking

• The governance of the bank should be adequately transparent to its shareholders,

depositors, other relevant stakeholders and market participants. The banks

disclosure should include, but not be limited to:

o Material information on the bank’s objectives,

o Organisational and governance structures and policies,

o Major share ownership and voting rights and related parties transactions

o Incentive and compensation policy

The Indian Banks have been complying with the Basel II requirements of pillar 2 & 3 from

2009 and 2010 respectively. Implementation of Basel II norms for pillar 1 has been taken up

in a sequential and progressive manner with the final implementation of advanced

approaches by 2014.

Important parameters relating to Corporate Governance in India

Bank Ownership

Interest of shareholders Vs Interest of Depositors-Conflict is between profits and safety of

deposits. Depositors and bank customers have little say in the governance of the banks,

while shareholders especially the promoters in case of private banks hold an important say

in the governance of the banks. Frequent agency problems can arise.

Public Vs. Private ownership- Issue arises because in India most of the banks are in public

sector.


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Accountability, Transparency and Ethics

Over the years measures have been taken to make boards more accountable to all

stakeholders and ensure transparency in their functioning. The separation of ownership and

management can create conflict of interest if there is a breach of trust by managers on

account of intention, omission, negligence or incompetence as we have seen on global

stage. But, we need to analyse using examples from different Indian banks as to whether

the voice of independent directors always independent? Do bank CEO’s countenance

criticism from the board? It is only through such soul searching that corporate governance

of banks can improve its effectiveness.

The failure on the scale we saw during the recent global financial crisis is also reflective of

poor ethical standards in banks. The behaviour of actors across the chain of the financial

sector was swayed by the opportunity for making quick profit rather than by fair, ethical and

moral standards. Neither were the sub-prime borrowers adequately warned that there was

a good chance of fall in asset prices nor did investment advisers tell their clients of the risk

they were taking in buying MBAs and CDOs. Such behaviour was not only checked, but was

even encouraged.

Compensation

Executive compensation for banking officials worldwide has two main components, salary

based and performance based commission. The performance based compensation is given

to the banking officials based on the basis of the profits made by the company in that fiscal

year. This generally leads to a tendency where the banking CEOs get myopic and take

unnecessary risks with the aim of booking only short term profits, and have total disregards

for the long term profits and welfare of the company. This has been attributed as one the

main reasons of the 2008 US recession which led to a financial turmoil worldwide.

The US Banking officials got short sighted and kept on lending to less credible borrowers,

and the Investment Bankers kept buying the risky CDOs and CMOs, as they were drawing

heavy compensation for the business being generated by them. This fuelled the entire

housing bubble, and when the bubble burst, it lead to the collapse of a lot of banks and the


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entire financial system. A cue of the same can be taken from the line and bar graph, shown

in Annexure 1 (cash flow). There was a sharp rise in the Wall Street bonuses in the early and

mid 2000 period when sub prime lending was at its peak that is just before the financial

crises.

After the 2008 financial crisis the executive compensation of Banking officials has come

under a lot of flak from different quarters and steps are being taken to bring in regulations

in this regard. Dodd-Frank Act is one of the acts passed in this regard. In March, 2011 SEC

moved forward a proposal requiring at least 50 percent of annual incentive compensation

for executive officers of large financial firms to be deferred for no less than three years. In

an attempt to realign banker’s bonuses with long term performance, the FDIC became the

first agency to implement the Dodd Frank requirement prohibiting financial institutions

from offering any compensation arrangements that could lead to material financial losses

for the company. Under the FDIC proposal, now supported by the SEC, the deferred portion

of annual incentive compensation can be paid no faster than on a pro-rata basis (i.e 1/3 per

year for three years).

One of the main reasons that India did not feel the heat of the 2008 crisis like the other

nations is because of the sound Corporate Governance laws in the Banking sector. The

central bank of India, RBI derives its power to intervene on issues such as compensation of

bank CEO’s from the Banking Regulation Act. In fact, the act empowers the RBI to even issue

directions to banks to fix salaries at a certain levels. It regulates the compensation packages

of the CEO’s of the banking officials, in line with the principles of the Financial Stability

Board (FSB) and Basel committee. According to the Banking Regulations Act, the RBI of India

has the power to regulate board compensation, including the pays and perquisites of the

CEOs of private sector banks. In evaluating compensation proposals for whole time directors

and CEO’s of private banks, the Reserve bank is guided by relevant factors such as

performance of the bank, compensation structures in the peer group, industry practice and

regulatory concerns. As regards to bonuses, in terms of the Reserve Bank guidelines issued

in August 2003, bonus in respect of whole time directors and CEO’s has been capped at 25

per cent of their salary or at the level of Bonus paid to other employees of the bank. Though


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the RBI does not have clear guidelines or parameters on CEO compensation in banks, it is

said to be guided by the size of the banks. Multinational banks, though under RBI’s

regulatory framework, escape such strictures. In India, according to a banker in a top private

bank, the CEO salaries can be broadly categorized thus as follows: Rs. 1 crore for public

sector banks (Approx. $200,000 USD); Rs. 2.5-3 crores ($500,000 USD-$600,000 USD) for

private sector banks and Rs 8-9 crores ($ 1,800,000 USD-2,000,000 USD) for foreign banks.

Governance and performance in Microfinance Institutions

Governance is about achieving corporate goals. For the MFI, multiple goals exist. The

fundamental goal is to contribute to development. This involves reaching more clients and

poorer population strata, the so-called main outreach 'frontier' of microfinance. A second

goal is to do this in a way that achieves financial sustainability, preferably independence

from donors.

There has to be separation of responsibilities of promoter/chairperson/CEO as chairperson

cannot play this role effectively if the same person is also running the daily operations as

CEO/MD. This defeats the very purpose of corporate governance.

Committees should be created which utilizes a well-defined board and addresses key issues.

There should be well-defined and clearly drafted procedures are essential for effective

governance.

Policy on MFIs and enabling environment

Now in India, there is an urgent need of a well-accepted Microfinance policy supported by

regulatory and supervisory framework, which is still missing at the cost of the stakeholders.

Finally, the importance placed on microfinance as a development instrument, combined

with the increasing inflow of capital/funds to the industry, indicates a need to better

understand governance systems for MFIs.

In recent times, there have been three cases that are important while studying corporate

governance in India because they signify a change in corporate governance practices in


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India. The cabinet approving the Companies Bill; Successor to Mr Ratan Tata being

announced; and Mr Akula had exiting SKS Microfinance Limited, a company founded by him.

The Bill has several corporate governance and disclosure norms. The new Companies Act

will be contemporary and will improve corporate governance practices, if implemented

effectively.

Succession planning is an important issue in corporate governance. Investors suffer when

the board of directors fails in its responsibility to identify the successor well in time. This

was demonstrated by naming the new successor of the TATA Group after Mr. Ratan Tata.

And, finally the exit of Mr Akula from SKS Micro finance Limited, the only listed micro

finance company, provides some lessons in corporate governance. The first is that holding

of majority voting rights by institutions does not necessarily improve corporate governance.

The company’s shareholding pattern as at September 2011 was: Promoters: 37%, FII 19%,

Indian Financial Institutions: 6%, Indian Bodies Corporate: 14%, Foreign Bodies Corporate:

12 % and others: 12%.

Effective corporate governance requires institutions to play their role effectively. That has

not happened in the case of SKS. Second is that the corporate governance system comes

under stress when a company deviates from its stated vision and mission.

The last learning from the SKS episode is that the Board should intervene immediately when

it senses rift in the management. It cannot take the approach of ‘wait and watch’. Such an

approach delays the intervention and causes huge damage to the company. The board has

to take harsh decisions well in time before the damage is done. I believe that the three

events of the previous week signals a ‘new dawn’ in the Indian corporate governance.


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Annexure 1-


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Annexure (Contd.)

(Source: Reserve Bank of India)


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References

Balasubramaniam, C S; Pradhan, Rudra Prakash (Dec 2005). ‘Corporate Governance and its

Role in Banking Sector’, Finance India

Chakarbarti ,Rajesh;Yadav ,Pradeep K. 'Corporate Governance In India' ,Journal of Applied

Corporate Finance

Gopinath, Shyamala (Jul 2008). ‘Corporate governance in the Indian banking

industry’, International Journal of Disclosure and Governance, suppl. Special Issue: Disclosure

and Governance Policies

Narayana, M Srinivasa; Sesha Mohan, V V (Nov 2007). ‘Corporate Governance in Indian

Banking Industry’, Institute of Cost and Works Accountants of India

Mckisney & Company (2007) Report on Indian Banking, Towards Global Best Practices

Prasun Kumar Das(2011). Towards Corporate Governance of Microfinance Institutions in

India. Working Paper No:SRM/KIIT/2

Websites

• http://business-standard.com/india/news/3-cheers-for-corporate-governance-

/456851/

• http://www.rbi.org.in/Scripts/PublicationReportDetails.aspx?fromdate=08/04/05&S

ecId=21&SubSecId=0

• http://www.expressindia.com/latest-news/Too-high-cut-CEO-pay-RBI-tells-three-

private-banks/470979/

• www.ibef.org

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