Justice, Transparency and Fair Compensation for Investors Affected by the Five-Bank Merger

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The Issue

Petition to the Hon'ble Prime Minister of the People's Republic of Bangladesh, the Governor of Bangladesh Bank, the Chairman of the Bangladesh Securities and Exchange Commission (BSEC), the Finance Adviser/Minister of the Ministry of Finance, the Chairman of the Anti-Corruption Commission (ACC), the Chairman of the Dhaka Stock Exchange (DSE) PLC, the Chairman of the Chittagong Stock Exchange (CSE) PLC, the Chairman of the Financial Reporting Council (FRC), the President of the Institute of Chartered Accountants of Bangladesh (ICAB), and all other competent authorities responsible for banking regulation, capital market supervision, financial reporting, corporate governance, auditing, and investor protection.

Protect Minority Shareholders. Restore Confidence in Bangladesh's Capital Market.
We, the undersigned investors of the Dhaka Stock Exchange (DSE), respectfully submit this petition on behalf of thousands of minority shareholders whose investments were effectively wiped out following the merger and resolution of five listed banks.

We invested in these banks based on official information published through Bangladesh's regulated capital market, including audited financial statements, quarterly financial reports, Net Asset Value (NAV) disclosures, annual reports, credit ratings, and other regulatory disclosures.

As ordinary investors, we trusted that these disclosures were prepared in accordance with the law and that the regulatory framework existed to promote transparency and protect investors.

The subsequent write-down of our shares to zero has caused devastating financial losses and raises serious questions that deserve transparent, independent, and evidence-based answers.

Investors Relied on Official DSE Disclosures
Investment decisions were made using information officially disclosed through the Dhaka Stock Exchange.

For example, EXIM Bank PLC publicly disclosed:

Audited Financial Statements (Published 29 May 2025)
For the year ended 31 December 2024:

  • Consolidated EPS: Tk. 0.18
  • Consolidated NAV per Share: Tk. 21.82
  • Consolidated NOCFPS: Tk. 0.56

Credit Rating (Published 30 July 2025)
CRISL assigned:

  • Long-Term Rating: A+
  • Short-Term Rating: ST-4
  • Outlook: Developing

The published disclosure stated that the rating considered:

Audited financial statements up to 31 December 2024;
Unaudited financial statements up to 31 March 2025; and
Other relevant quantitative and qualitative information.
Third Quarter Financial Statements (Published 2 November 2025)

EXIM Bank further reported:

  • Consolidated NAV per Share: Tk. 19.54
  • Consolidated NOCFPS: Tk. 20.80
  • Consolidated EPS (January–September 2025): Tk. (2.17)

These disclosures remained available through the official DSE disclosure platform and formed part of the information upon which investors reasonably relied.

Official Recognition by Bangladesh Bank
In July 2024, Bangladesh Bank published its Sustainability Rating 2023, in which EXIM Bank PLC was included among Bangladesh's Top Sustainable Banks. The report assessed banks on sustainability-related indicators such as governance, sustainable finance, environmental and social risk management, and disclosure practices. The banks were listed alphabetically rather than by numerical rank.

Although a sustainability rating is different from a financial soundness assessment, this official recognition reinforced investor confidence and forms part of the broader information environment in which investment decisions were made.

The subsequent elimination of shareholder value therefore raises important questions regarding the timing, transparency, and communication of the bank's financial condition.

Questions That Deserve Independent Answers
We respectfully request answers to the following questions:

  • If the published audited and quarterly financial statements reported positive Net Asset Value, how was shareholders' equity ultimately written down to zero?
  • When did the financial condition of the banks deteriorate to the point where shareholders had no remaining value?3
  • Were material impairments, non-performing assets, provisioning requirements, capital deficiencies, and other significant risks reflected promptly and accurately in public disclosures?
  • Were investors provided with timely information about any material deterioration before the merger and resolution process?
  • What valuation methodology and assumptions were used to determine that shareholders' equity should be written down to zero?
  • Were the audited and unaudited financial statements prepared in accordance with applicable accounting standards?
  • Were external audits conducted in accordance with applicable professional standards?
  • Were disclosure obligations, corporate governance requirements, and regulatory responsibilities effectively discharged?
  • These questions do not presume wrongdoing. They seek a transparent determination of the facts in the public interest.

Our Demands
We respectfully call upon the Government of Bangladesh and all relevant authorities to:

  1. Establish an independent forensic audit of the five merged banks.
  2. Publish the complete valuation reports, methodologies, assumptions, and supporting analyses used in determining the write-down of shareholders' equity.
  3. Review the consistency between published financial statements and the financial conclusions reached during the resolution process.
  4. Examine whether all applicable accounting, auditing, disclosure, corporate governance, and regulatory requirements were complied with.
  5. Determine, through due process, whether any failures, negligence, misconduct, or breaches of law contributed to investor losses, and take appropriate action where warranted.
  6. Strengthen disclosure requirements, supervisory coordination, and investor protection measures for listed financial institutions.
  7. Restore confidence in Bangladesh's banking system and capital market through greater transparency and accountability.
  8. Fair Compensation for Affected Investors
  9. Thousands of minority shareholders invested their life savings in reliance on information that was officially disclosed through Bangladesh's regulated capital market.

If an independent investigation or a court determines that investors suffered losses because of material misstatements, inadequate disclosures, breaches of statutory duties, professional negligence, regulatory failures, or other unlawful conduct, affected investors should receive fair and appropriate compensation in accordance with the law.

We therefore respectfully request that the Government and the relevant authorities:

  • Develop a fair compensation or restitution mechanism for affected minority shareholders if liability is established.
  • Consider establishing an investor relief or compensation fund where legally appropriate.
  • Ensure that investors are not left to bear the entire burden if investigations conclude that legal or regulatory obligations were breached.
  • Pursue recovery from any persons or entities found legally responsible, consistent with due process and applicable law.
  • Investor protection requires not only transparency and accountability but also meaningful remedies when legal responsibility is established.

Why This Matters
A healthy capital market depends on trust.

Millions of Bangladeshis invest based on the expectation that official financial disclosures are reliable and that regulatory systems promote transparency and fairness.

An independent review of these events is essential to restore confidence, strengthen governance, and protect future investors.

This petition does not seek to prejudge the responsibility of any individual or institution. Rather, it seeks a fair, impartial, and evidence-based investigation, followed by appropriate action and remedies consistent with the findings.

Sign This Petition
If you believe that:

  • Investors deserve transparent financial reporting;
  • Minority shareholders should be treated fairly;
  • Public confidence in Bangladesh's capital market must be restored; and
  • Those who suffer losses because of proven legal or regulatory failures should have access to fair remedies,

then please sign and share this petition.

Transparency. Accountability. Investor Protection. Fair Compensation.

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