Business Human Rights Resource Centre
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View as list ABSA Anjin Investments Atalaya Mining BHP Billiton Finance Chemical Bank Citigroup Essar Global Fund Export Credit Insurance Corporation of South Africa First Mining Gold Industrial Development ING Investec Iran Foreign Investments Japan Bank for International Cooperation JP Morgan Chase Maxit Capital NCCL Natural Resources Investment Fund (owned by China Molybdenum/CMOC International) Nedbank Noble Group Rand Merchant Bank Redbird Capital Partners Resource Capital Funds Royal Bank of Canada South32 Standard Bank UBS Vanguard Precious Metals and Mining Fund Volcan Investments Xtract Resources ZCCM Investments Holdings
1. Policies & Procedures           Our Environmental and Social Policy Framework [https://www.citigroup.com/citi/sustainability/data/Environmental-and-Soc... is a publicly available synthesis of all existing policies relevant to our human rights due diligence of our clients and projects......         See our response to question 3 Investec has a deeply-rooted tradition of active corporate citizenship and we are mindful of our responsibility to live in society and not off it. As a distinctive financial institution with specialist skills in lending and investing, we play a critica......           Nedbank has a Social and Environmental Management system developed in collaboration with the International Finance Corporation that aligns with global benchmark frameworks, including but not limited to the IFC Performance Standards, the Equator Princip......   Rand Merchant Bank (RMB) is a division of FirstRand Bank Limited. As a result, all RMB transactions go through an ‘Environmental and Social Risk Assessment’ (ESRA) as required by FirstRand’s Group policy. Please see FirstRand Limited’s latest ‘Environm......       South32 is a globally diversified mining and metals company. We produce 10 commodities across our operations in Australia, Southern Africa and South America. We are also the owner of a high-grade zinc, lead and silver development option in North Americ......   We transparently disclose our policies and procedures in our comprehensive Environmental & Social Risk (ESR) Policy Framework document which can be downloaded from https://www.ubs.com/global/en/about_ubs/ubs-and-society/downloadcenter/2...        
2. Human Rights Due Diligence           Citi’s Environmental and Social Risk Management (ESRM) Policy fully incorporates the Equator Principles (EPs) (co-founded by Citi in 2003) to determine, assess and manage environmental and social risks for project-related finance. The EPs form the back......         Yes. All new clients in the extractive sector undergo Know Your Client Screening that includes an ESR Client Assessment. Depending on our level of engagement (providing general financing facilities to the client or financing specific assets) ESR Assess...... Yes: The environmental and social standards for clients in these sectors consist of minimum requirements and benchmark criteria. Investec will only engage with clients who comply with all applicable minimum requirements within their jurisdictions, or h......           Within the corporate lending space which includes structured finance i.e. project finance, we appoint specialists to conduct such assessments on a deals by deals basis. The environmental manager responsible for the transaction will need to investigate ......   Yes, new projects in the extractive industry will be subject to an independent Equator Principles Review (including a review against the IFC Performance Standards) as detailed in the previous response. Funding to clients in the extractive industry tha......       As a global resources company, we have interests in exploration companies and also conduct exploration for new projects. As part of the process to develop resources from exploration to an operation, we adhere to our internal standards, which include co......   UBS applies an environmental and social risk framework to all transactions, products, services and activities such as lending, capital raising, advisory services or investments that involve a party associated with environmentally or socially sensitive ......        
3. Human Rights Issues           For transactions in high-income OECD countries, Citi requires compliance with all relevant local and national environmental laws, including those on impact assessment, public consultation and stakeholder engagement processes, and permitting conditions.......         Human rights issues that are included in our risk assessment very much depend on the size, nature and location of the project and related impacts. Those would have been identified in the Environmental and Social Impact Assessment (for projects) or appl...... We support the 10 principles of the UN Global compact, which includes the following Human Rights Principle 1: Businesses should support and respect the protection of internationally proclaimed human rights; Principle 2: make sure that they are not comp......           Within the corporate lending space, when a need is identified to analyse human rights risks to a project or to a client’s operation (where appropriate), a human rights specialist will provide a report in line with the IFC sustainability framework and t......   Please see the IFC Performance standards but to name a few - forced labour, child labour, modern slavery, victimization, gender discrimination, forced resettlement without consent, non-consideration of indigenous people’s rights, working conditions, et......       As a resources company, we conduct human rights and social impact baselines for projects to provide us with input into our assessment of the potential social and community impacts. These initial profiling exercises draw on publicly available social, de......   Any salient human rights infringements is potentially in scope of our assessments. See the "3. Our Standards" section of our ESR Policy Framework document for details on issues where we have defined a specific standard.        
4. Sector Specific Policies           We do have certain sector approaches (see pp. 7-8 of Policy Framework) that apply distinct, well-established sector-focused best practices or industry standards to projects and clients in that sector (e.g., RSPO for palm oil clients, among others).  Ou......         Yes, please see page 26 of our ESR Framework, ESR Sector Policies, Mining & Metals https://www.ing.com/Sustainability/Sustainable-business/Environmental-an... We have identified certain controversial activities we will not engage in, or will only participate under stringent criteria. As part of this process we engage with client and suppliers to further understand their processes and policies and to explore ......           Nedbank has a Human Rights in Business Policy as well as a sector policy for mining but we do not have a separate human rights policy/guidelines for the mining sector.   Yes, each project is considered on its own merits. FirstRand also has various internal position statements and funding exclusions many of which are relevant to the mining sector such as conflict minerals, forced and child labour, cross border movement ......       South32 applies our policies in a consistent manner across our portfolio, including where exploration activities develop into operations.   We apply a cross-sector approach and our criteria applies for all sectors, including mining. Again see "3. Our Standards" section in the ESR Policy Framework document.         
5. Country Specific Policies           Our main distinctions are focused on broad categories of development/income status, following the approach in the Equator Principles. However, we do not apply the Equator Principles’ distinction between Designated and Non-Designated Countries in the co......         Country risk is an integral component of our risk management. We respect sanctions imposed by the United Nations, the European Union or any other legislated sanctions that apply to the countries in which the bank operates. ING will not undertake any tr...... We do not have country specific policies for any countries or areas in Southern Africa, however, projects in Organisation for Economic Cooperation and Development (OECD) countries have to comply with a high level of environment, planning, labour and pr......           The Nedbank Human Rights in Business Policy is applied across jurisdictions unless the Human Right’s legislation in a particular country is stronger than the Nedbank policy. In this case the stronger of the two would be applied.   Yes, we do have ESRA policies that are tailor made for each country that refer the ESRA reviewer to relevant guidance such as the IFC Performance Standards and associated guidelines as well as Group funding exclusions and position statements.       South32 adapts its approach to human rights impact assessments depending on the country of operation to recognise the higher levels of risk that exist in certain jurisdictions in which we operate. For example, at our South Africa, Mozambique and Colomb......   Our ESR Policy Framework is global. We have our universal criteria (see "3. Our Standards" section in the ESR Policy Framework document) which is applied globally.           
6. Assessment Responsibility           (see p. 5 of Policy Framework): Implementation of the ESRM Policy is a shared responsibility across Citi: ESRM unit – The ESRM unit serves as a global technical resource and in-house counsel for risk managers, senior management, and bankers. ESRM Cha......         We have a dedicated global Environmental and Social Risk team responsible for assessing environmental, social and human rights risks at ING. This team reports to the Chief Risk Officer. We have Account Managers, and product specialists, who serve our ...... The social and ethics committee (SEC) is responsible for monitoring the non-profit elements of sustainability. Our commitment to corporate responsibility means integrating social, ethical and environmental considerations. For Investec, being a good cor......           The Human Rights Policy was developed within Enterprise, Governance and Compliance Cluster for the Nedbank group. It is implemented through the Social and Environmental Management System in the various client-facing clusters. Each of the client-facing ......   For all moderate to high risk Equator Principle transaction, an independent and competent environmental consultant conducts the review. For all other transaction, in-house ESRA reviewers conduct reviews. Please see FirstRand Limited’s latest ‘Environme......       As a resources company, we identify, assess and manage our human rights risks. We have an internal Human Rights Specialist who manages South32’s human rights strategy, including our modern slavery in supply chains work. We have an internal Community M......   See " 4. Our processes and governance" (pages 4-6) in our ESR Policy Framework document.         
7. Grievance Mechanism           Yes – this would be considered a requirement for development of any large-scale extractive project and would be incorporated into a client’s Environmental and Social Action Plan that would then be included in a binding covenant in project-related loan ......         We require companies to have grievance mechanisms in place for each extractive project that is financed by ING, and in our overall assessment of companies operating extractive projects, we ask whether they have a: “Stakeholder Engagement Strategy or Gr...... In South Africa before mining rights are granted, a company needs to submit and comply to “A Social and Labour Plan” before the Department of Mineral Resources (DMR) will grant a mining right. The DMR regularly audit these. We regularly receive updates......           Yes for all extractive industry clients regardless of whether it is a corporate or a project finance transaction a grievance mechanism is required. In high impact industries such as the mining industry, a grievance procedure is part of the consultation......   Yes, grievance mechanisms are a requirement in terms of the Equator Principles/IFC Performance Standards. A grievance mechanism needs to be applied at ground level at all phases of a project i.e. prior to construction, during construction, during opera......       As a resources company, South32 has complaints and grievance mechanisms at each of our existing operations and we also make available EthicsPoint, an independent external platform for employees and contractors to anonymously report concerns regarding p......   Same as for question 2, this would be one of the factors looked at in an enhanced DD. And again: Please note that UBS is not engaged in direct project finance outside of Switzerland.         
8. Remediation Steps           Yes, we do so on a routine basis. See, e.g., case study on a gold mining company in Russia in our 2017 Global Citizenship Report, p. 51. We have worked with large infrastructure projects to raise labor standards for subcontractors such that subcontract......         Yes, we did. No.           Yes, should there be allegations of non-compliance with any legislation, not just human rights, against a client Nedbank works with that client to develop appropriate action plans to resolve said issues.   We are not yet at a stage where we can apply sustainably performance linked loans but we are considering this. At this stage, we expect clients to remediate any material issues prior to us providing funding given that human rights issues would be seen ......       As a resources company with projects and existing operations, we work with stakeholders from our existing operations, such as local community members and our suppliers, to support human rights related remediation actions. An example of this is work we......   Yes        
9. Withholding Finance           Yes. See Citizenship Report p. 48 as an example          Yes, we did. Reasons for not accepting a company or approving a loan can vary from, but is not limited to: Poor environmental and social performance of the company implying lack of capacity and commitment to manage human rights impacts related to its ...... No.           Yes.   Yes, if our initial ESRA review identified material human rights concerns, we have not pursued the funding or applied restrictions on funding allowed. An example of this is not funding certain companies in certain jurisdictions for environmental and so......       As a global company, we assess potential new jurisdictions and investment options based on risk.  For this reason, we have assessed that the Democratic Republic of Congo is not a place we can operate in and maintain our own internal standards. In an ar......   Yes See table on page 5 of the ESR policy framework document where we disclose the number of referrals to our environmental and social risk unit that were rejected or not further pursued. E.g. in 2017, 2170 referrals were assessed by our environmental ......        
10. On the Ground Assessments           All Category A and certain Category B EP-covered project finance transactions, and any EPcovered project related corporate loans that trigger EP 7 “high risk impacts” Citi requires review by an independent environmental and/or social expert with releva......         Our Account Managers for the Extractive Sector are well aware of the need for good assessment of environmental, social and human right risks at both client and asset level. They therefore undertake site visits at client & asset level to see the ope...... We require that projects comply with the applicable environmental, planning, labour and procurement laws. Where there is a potential significant/limited adverse social or environmental impact, we will expect the projects to undergo the suitable risk an......           Within the corporate lending space, we do periodically visit the project sites in conjunction with independent Environmental Practitioners. Where issues are flagged whether environmental or social the internal Nedbank Social and Environmental Risk Mana......   Yes, site visits to project sites both before funding and during the term of a loan is an Equator Principles requirement. Environmental and social requirements/actions are also included as covenants in the loan agreement. In-house ESRA staff also condu......       As outlined above, we complete a range of ongoing human rights due diligence activities for our existing operations and complete initial community and social investigations for potential projects, which are a starting point for a more comprehensive, fo......   Please note that UBS is not engaged in direct project finance outside of Switzerland. In certain cases, UBS would ask for an on the ground assessment by an independent expert / consultant.        

1. What policies and procedures does your institution have to undertake human rights due diligence regarding the companies and projects it finances, beyond what is publicly available on your website?

2. Do you require new clients or new projects in the extractives sector to have undertaken human rights due diligence prior to providing financing?

3. Which human rights issues are included in your risk assessment process for extractive projects?

4. Does your institution adapt its human rights policies and procedures for the specific sector of investment in order to account for the varied risks across sectors? If so, do you have specific policies on the mining sector?

5. Does your institution adapt its human rights policies and procedures for the specific country of investment in order to account for the varied risks across nations? If so, do you have specific policies for any countries or areas in Southern Africa?

6. Who assesses human rights risks at your bank (departments, positions, internal/external, etc.)?

7. Do you require companies to have grievance mechanisms in place for each extractive project and if so, what do you see as essential in an effective grievance mechanism?

8. Have you ever taken any steps to require or support a client in remediating a human rights impact?

9. Have you ever withheld loans or other financial services as a result of a human rights assessment or allegation?

10. Do you undertake any form of on the ground assessment of conditions at project sites?

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